Debra Devereaux

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Usually CMS leaves us wondering about the benchmark that they have in mind for plans to achieve.  But the latest 2013 Draft Call Letter left little to the imagination. 

It states, “We expected more Part D beneficiaries would be eligible for MTM following changes to the eligibility criteria requirements in 2010. However, the eligibility rate has remained at 10 to 13% since 2006. We are concerned that the Part D sponsors are restricting their MTM eligibility criteria to limit the number and percent of beneficiaries who qualify for these programs and are required to be offered CMRs.”

By reading the tea leaves, one can surmise that CMS thinks a ten to thirteen percent (10%-13%) MTM eligibility rate is not high enough. CMS is further adding the percentage of Comprehensive Medication Reviews as a Part D star measure and adding Alzheimer’s and End Stage Renal Disease with dialysis as chronic conditions. There is a required MTM format now and increased emphasis on increased contact with members to get them to agree to a Comprehensive Medication Review.

When considering Medication Therapy Management program criteria to be submitted (due May 7, 2012), organizations should consider expanding the program criteria so that more members are eligible and requiring their MTM vendor or their internal staff providers to get the Comprehensive Medication Review numbers way up.  This time CMS has given us a good look at where the bar is.

Debra Devereaux

About Debra Devereaux

Deb Devereaux brings to Gorman Health Group clients extensive Medicare and Medicaid prescription drug operational leadership experience. Her tenured experience has been sought by numerous health plans, PDPs and PBMs. Read more

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