McMillan, Matt -- FL

Document ID: CMS-2011-0157-0519
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: May 13 2012, at 12:00 AM Eastern Daylight Time
Date Posted: June 20 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: April 12 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: June 11 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 8100bec3
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This is comment on Rule

Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs for Contract Year 2013 and Other Changes

View Comment

To protect the interests of the Long Term Care residents LTC pharmacists must be freed from all potential conflicts of interest. This means a separation of of the LTC pharmacy from the LTC pharmacist is required for a truly independent drug regimen review(DRR). The number of ways the employer LTC pharmacy can apply pressures on the employee pharmacist in making drug regimen review (DRR) reccomendations are far too many to describe in the confines of this comment. Minimum quotas in terms of reviews, adopting "preferred" formulary reccomendations, "bonus" payment incentives, continued employment or termination are just a few of the widely acknowledged ways LTC pharmacies exert undue influence over their employee pharmacists. By not requiring the separation of LTC pharmacy services from LTC pharmacist services it places the LTC residents in jeopardy by denying their entitlement to an independent review of their medications by a LTC pharmacist.