It is preposterous that a contracted pharmacy in a long term care facility may be its own agency of oversight for purposes of "independent review"
I cannot imagiine how that might in any way be considered "independent."
The lives and proper care of residents depends on having REAL oversight by an independent professional whot has NO interest in the profitability of the facility or their own pharmacy billing.
That is simply not possible if the contracted pharmacy is the "independent review" pharmacy.
Gelbman, Doris -- VA
This is comment on Rule
Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs for Contract Year 2013 and Other Changes
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