OH

This comment is directed to CMS to include clinical Pharmacists as part of a collaborative care model for inclusion for both recognition and payment mandate under the ACO Medicare shared savings program. Under Health Care Reform, Medication Therapy Management (MTM) is identified in 16 different places to be delivered by pharmacists. The AMA CPT code book has Pharmacists codes only for MTM. I have been practicing at Family Medicine sites collaboratively with physicians since 1998. First it is inappropriiate that pharmacists are not mentioned as a sign in designation for this section. Second, ACO's need to include pharmacists as a part of the bundle of clinical care delivered. My clinical outcomes that I have been gathering over the past 12 years shows that vs NHANES data, 4x success vs standard care. I asked that clinical pharmacist be recognized and compensated for delivering collaborative clinical MTM services. Please contact me at allennichol@aol.com or 614 506 8128 for questions. I am in utter disbelief that since their are 130 colleges of pharmacy in the US and licensure requirements in all 50 states and US territories that US government continues to ignore the clinical contributions that are documented in thousands of peer review journal articles. I co authored one of these articles in the Journal of the American Pharmacist Association in January of 2006; The Pharmacist as Physician Extender. I suggest changes to include clinical pharmacist as previously mentioned. Allen Nichol, Pharm.D. VP Clinical Operation COO CeutiCare LLC