VIA Electronic Submission to

Similar documents
Re: Voluntary 2015 Edition Electronic Health Record (EHR) Certification Criteria; Interoperability Updates and Regulatory Improvements

The following are our comments regarding the Draft Trusted Exchange Framework.

Draft 2014 CMS Advanced Notice and Call Letter to Medicare Advantage and Part D Prescription Drug Plans

EHR Data Integration and Seamless Exchange of Clinical Information to Enable Next-Generation Pharmacy Services

IMPROVING MEDICATION RECONCILIATION WITH STANDARDS

Statement of Ronna B. Hauser, Pharm.D. Vice President, Policy and Regulatory Affairs National Community Pharmacists Association

Insights into Pharmacist Provided MTM Services-Present and Future

Medication History for Hospital Settings: Better Data, Better Decisions. Tuesday, March 25, 2014 Pharmacy Town Hall Series

Benefits of National Provider Identifier

Leading By Example. Begin with a vision. Disclosures. Learning Objectives 3/25/2017. Tripp Logan, PharmD

March 3, i. Medication Reconciliation Post Discharge (Part C) (p. 79)

eprescribing Information to Improve Medication Adherence

Pharmacy Quality Measures. Presentation Developed for the Academy of Managed Care Pharmacy Updated: February 2013

Re: HHS-OS HIT Policy Committee: Request for Comment Regarding Stage 3 Definition of Meaningful Use of Electronic Health Records (EHRs)

Via Electronic Submission to:

December 12, [Submitted online at:

Medication Therapy Management

ONC Cooperative Agreement HIE Program Update. Arizona Rural & Public Health Policy Forum January 19, 2012

MEANINGFUL USE FOR THE OB/GYN. Steven L. Zielke, MD 6/13/2014

Measures Reporting for Eligible Providers

Measures Reporting for Eligible Hospitals

Eligible Professionals (EP) Meaningful Use Final Objectives and Measures for Stage 1, 2011

MTM Performance & Impact On Star Ratings 2016 & Beyond - OutcomesMTM Overview

Meaningful Use: Review of Changes to Objectives and Measures in Final Rule

Medicaid Electronic Health Records Meaningful Use. Lisa Reuland, Program Manager October 15, 2015

Welcome! Today s Call Will Begin Shortly. Before we begin, please dial in from a telephone (not through your computer).

9/28/2011. Learning Agenda. Meaningful Use and why it s here. Meaningful Use Rules of Participation. Categories, Objectives and Thresholds

Medication Therapy Management (MTM) Solution

Disclosures. Attendance Code. Development and Support. Accreditation Information. House of Delegates Policy Topic Webinar Point of Care Testing

ecw and NextGen MEETING MU REQUIREMENTS

Disclosures. Learning Objectives 4/26/2017. Impact of a Pilot Ambulatory Care Pharmacist in a Family Practice Clinic

Request for Proposal: Primary Medication Non-Adherence

Overview of Current and Future Coding. PSTAC May 18, 2010 Presentation Prepared by: Shelly Spiro

B. Douglas Hoey, RPh, MBA. CEO National Community Pharmacists Association

AHA Survey on Hospitals Ability to Meet Meaningful Use Requirements of the Medicare and Medicaid Electronic Health Records Incentive Programs

Enhancing E Prescribing and Medication Adherence in the CT Medicaid Population

Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2013 [File Code CMS 1590 P]

Meaningful Use Stage 2 Timeline Monday, 27 August :29

ARRA New Opportunities for Community Mental Health

AHEAD OF THE CURVE. Top 10 Emerging Health Care Trends: Implications for Patients, Providers, Payers and Pharmaceuticals

Meaningful Use Stage 2 For Eligible and Critical Access Hospitals

Re: 42 CFR Part 485; Medicare Program; Conditions of Participation (CoPs) for Community Mental Health Centers

Fundamentals of Medication Therapy Management (MTM) Services By Bruce R. Siecker, Ph.D., R.Ph.

URAC Patient Centered Medical Home

Thought Leadership Series White Paper The Journey to Population Health and Risk

CMS Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Final Rule Overview

Medicare & Medicaid EHR Incentive Programs HIT Policy Committee May 6, 2014

THE NATIONAL QUALITY MEASUREMENT AND IMPROVEMENT AGENDA

Automation and Information Technology

Agenda 2. EHR Incentive Programs 3/5/2015. Overview EHR incentive programs Meaningful Use Differences between Stage 1 and Stage 2

The HITECH EHR "Meaningful Use" Requirements for Hospitals and Eligible Professionals

June 25, Dear Administrator Verma,

Issue Brief. E-Prescribing in California: Why Aren t We There Yet? Introduction. Current Status of E-Prescribing in California

Role of e-prescribing in Preventing Opioid Abuse

HIE Implications in Meaningful Use Stage 1 Requirements

June 27, CMS 5517 P Merit-Based Incentive System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule

Medicare & Medicaid EHR Incentive Programs

Tools for Providers. Clinical Care and Practice AdvancementElectronic Health Records (EHR)

American Recovery & Reinvestment Act

Overview of the EHR Incentive Program Stage 2 Final Rule published August, 2012

The Pharmacists Patient Care Process: Where Does Technology Fit?

Russell B Leftwich, MD

Expansion of Pharmacy Services within Patient Centered Medical Homes. Jeremy Thomas, PharmD Associate Professor Department Pharmacy Practice

TRANSITIONS of CARE. Francis A. Komara, D.O. Michigan State University College of Osteopathic Medicine

Eligible Professional Core Measure Frequently Asked Questions

What Will Stage I Mean for Consumers and Purchasers

Transforming Health Care with Health IT

Patient Centered Medical Home. History of PCMH concept. What does a PCMH look like? 10/1/2013. What is a Patient Centered Medical Home (PCMH)?

CMS-0044-P; Proposed Rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program Stage 2

SUBMIT/RECEIVE STATEWIDE ADMISSION, DISCHARGE, TRANSFER (ADT) NOTIFICATIONS

EHR Incentive Programs for Eligible Professionals: What You Need to Know for 2016 Tipsheet

Medicare and Medicaid Programs: Electronic Health Record Incentive Program -- Stage 3 and Modifications to Meaningful Use in 2015 through 2017

Meaningful Use: Introduction to Meaningful Use Eligible Providers

HIT Glossary and Acronym List

Meaningful Use of EHR Technology:

Stage 1 Meaningful Use Objectives and Measures

Objectives. Medication Therapy Management: The Important Role of the Pharmacy Technician. Medication Therapy Management (MTM)

UPDATE ON MEANINGFUL USE. HITECH Stimulus Act of 2009: CSC Point of View

PATH Program. Getting Started Guide

Medicare Part D Member Satisfaction of the Comprehensive Medication Review. Katie Neff-Golub, PharmD, CGP, CPh WellCare Health Plans

2017 House of Delegates Report of the Policy Committee

Medicare Beneficiary Quality Improvement Project

[Document Identifiers: CMS-10341, CMS-10538, CMS-R-153, CMS and CMS-10336]

Network Participation Agreement

Stage 1 Changes Tipsheet Last Updated: August, 2012

Expanding Your Pharmacist Team

Meaningful Use Stage 2 Strategies. Presented by: C. Johnson, BS-HSA

Medicare & Medicaid EHR Incentive Programs

Proposed Meaningful Use Incentives, Criteria and Quality Measures Affecting Critical Access Hospitals

Educational. PPCP Foundations 3/5/17. Integrating the LLM / JCPP-PPCP in Experiential Education. Session Objectives

Medicaid Provider Incentive Program

Medicaid Efficiency and Cost-Containment Strategies

A Clinically Integrated Network. R.W. Chip Watkins, MD, MPH, FAAFP Independent Affinity Group 3 March 2015

Overview of CMS HIT Initiatives. Kelly Cronin Senior Advisor to the Administrator Centers for Medicare and Medicaid Services September 2005

Coastal Medical, Inc.

=======================================================================

Re: CMS Medication Therapy Management Program Improvements

Pharmacists Improve Care Through Team Collaboration

EHR/Meaningful Use

PATIENT SELF-MANAGEMENT CREDENTIALING AND VALUE-BASED HEALTH BENEFIT DESIGN CONSIDERATIONS IN PATIENT-CENTERED, TEAM-BASED CARE

Transcription:

VIA Electronic Submission to http://www.regulations.gov/#!documentdetail;d=cms-2012-0145-0001 December 27, 2012 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-9962-NC P.O. Box 8010, Baltimore, MD 21244-8010 Re: Request for Information Regarding Health Care Quality for Exchanges Overview of the Pharmacy e-health Information Technology Collaborative and Comments in Response to Request for Information Regarding Health Care Quality for Exchanges On behalf of the membership of the Pharmacy e-health Information Technology Collaborative (Collaborative), we are pleased to submit comments regarding the pharmacist s role in Health Care Quality for Exchanges. The Collaborative respectfully submits responses to the following questions: What quality improvement strategies do health insurance issuers currently use to drive health care quality improvement in the following categories: (1) improving health outcomes; (2) preventing hospital readmissions; (3) improving patient safety and reducing medical errors; (4) implementing wellness and health promotion activities; and (5) reducing health disparities? Response: Pharmacists work closely with health insurers concerning health care quality improvements. Through medication adherence and medication management programs that they provide, pharmacists are able to help patients improve their health outcomes and prevent hospital readmissions because their medications are used appropriately. Pharmacists also provide wellness and health promotion programs as part of their many patient-centered care services. To fully achieve the desired health outcomes of the federal Health IT Strategic Plan, however, the Office of the National Coordinator for Health Information Technology (ONC) must consider Pharmacy e-health Information Technology Collaborative 401 Holland Lane Suite 702 Alexandria, VA, 22314 www.pharmacyhit.org 571-312-2904

the inclusion of pharmacists as a component of Electronic Health Record (EHR) information exchange, which currently is not the case. The Pharmacy e-hit Collaborative believes that the inclusion of pharmacists clinical services and the use and exchange of patient clinical data are critical to achieving the new focus areas identified by the ONC, including Goal I of the Strategic Plan to foster and support current and new exchanges. One way to achieve the desired health outcomes of the Strategic Plan is to incorporate pharmacist-specific quality metrics adopted by the Pharmacy Quality Alliance (PQA). PQA is the bridge between health insurers and medication management. PQA measures also encompass smoking cessation, blood pressure monitoring, and appropriate use of medications for the prevention of heart attacks, all of which support ONC s overall objective to reduce and prevent heart attacks and achieve other desired health outcomes. The Collaborative supports information exchange that allows pharmacists to provide patientcentered care and to exchange medication information beyond that which is available for the purposes of electronic prescribing. Using e-hit in this manner will provide better documentation so that quality can be measured. Inclusion of pharmacists as meaningful users of EHRs also will help achieve ONC s Goal II of sharing information and care coordination to prevent unnecessary hospitalizations. 1 A key study demonstrating the positive benefit of pharmacists in preventing heart attacks is shown in the results from ProjectImPACT: Hyperlipidemia (Improve Persistence and Compliance with Therapy) sponsored by the American Pharmacists Association Foundation. This study demonstrates the positive outcomes associated with pharmacists clinical interventions working in collaboration with physicians to achieve the goals of the National Cholesterol Education Program (NCEP) in 397 patients in 12 states with hyperlipidemia over the period of 1996-1999. 2 Finally, pharmacists are easily accessible by individuals in all communities, including those that may not otherwise have access to other health care providers, which can mean reduced health care disparities. What challenges exist with quality improvement strategy metrics and tracking quality improvement over time (for example, measure selection criteria, data collection and reporting requirements)? What strategies (including those related to health information technology) could mitigate these challenges? Response: One of the challenges that exists, especially for pharmacists, is having to use prescription claims-based data captured by health insurers and other payers to obtain quality measures. The Pharmacy e-hit Collaborative strongly recommends moving away from the sole 1 Bluml BM, McKenney JM, Cziraky MJ. Pharmaceutical Care Services and Results in ProjectImPACT: Hyperlipidemia. J Am Pharm Assoc 2000; 40:157-65. 2 Ibid. 2

use of claims-based data to incorporating the use of patient clinical data to obtain quality measures, as well. The use of patient clinical data by pharmacists would provide a more meaningful and robust quality measure. Most claims submitted to health insurers or other payers that are used in claims-based data do not take into account cash payments, nonprescription medications, herbal alternatives, or other supplements used by patients as part of their health care regimen. Because pharmacists provide patient-centered care, they have access to meaningful patient clinical data and the ability to document such for improving quality measures. As the adoption of e-hit improves, the use of the SNOWMED CT standard vocabulary to gather patient care data will lead to improved quality measures. Describe current public reporting or transparency efforts that states and private entities use to display health care quality information. Response: As mentioned in the response to the previous question, one of the reporting mechanisms used by states and private entities for health care quality information is claimsbased data. From a medication perspective, using claims-based data only indicates that the patient receives a prescribed medication. Claims-based data does not show if the patient is taking nonprescription medications, herbal alternatives, other health supplements, or paying cash. It also is incomplete patient data on which certain quality measures are being based for affecting desired health outcomes. Additionally, claims-based data does not take into account other aspects for exchanging critical health information and improving health outcomes (e.g., is the dosage too high or too low). As incentivized meaningful users of electronic health records and information exchanges, EPs, EHs, and CAHs are gathering health care quality information and adopting quality measure sets. Pharmacists, however, are not receiving incentives to adopt these quality measures, although they are collecting health care quality information and clinical patient data and need to be able to access and exchange information with EPs, EHs, other providers, and private entities. Areas in which pharmacists collect this information for improving health outcomes and quality measures include Medicare Part D and immunizations. Again, the Collaborative believes that the inclusion of pharmacists clinical services is critical to achieving the new focus areas identified by the Office of the National Coordinator for Health Information Technology (ONC) Federal Health IT Strategic Plan, including Goal I of the Strategic Plan that is to foster and support current and new exchanges. 3

What are the priority areas for the quality rating in the Exchange marketplace? (for example, delivery of specific preventive services, health plan performance and customer service)? Should these be similar to or different from the Medicare Advantage five-star quality rating system (for example, staying healthy: screenings, tests and vaccines; managing chronic (longterm) conditions; ratings of health plan responsiveness and care; health plan members complaints and appeals; and health plan telephone customer service)? Response: The Pharmacy e-hit Collaborative supports the work being done by the PQA, which helps document Medicare s five-star rating on services provided by pharmacies. As noted previously, the Collaborative encourages movement away from claims-based data to patient clinical services data for EHR quality measures. The majority of patient medication management conducted by pharmacists is for Medicare eligible patients, and they are taking more medications. Pharmacists quality measures track closely to the Medicare rating system. The Collaborative would encourage and support the development of a rating system that could be used for the general population that will be served by Exchanges, in order to facilitate continuity of care. ************ Formed in the fall of 2010, the Collaborative s focus is to assure the meaningful use (MU) of standardized electronic health records (EHRs) that supports safe, efficient, and effective medication use, continuity of care, and provides access to the patient-care services provided by pharmacists with other members of the interdisciplinary patient-care team. The Collaborative s goal is to assure that the pharmacist s role of providing patient-care services is integrated into the National HIT interoperable framework. The group is pursuing EHR standards that effectively support the delivery, documentation of, and billing for pharmacist-provided patient care services across all care settings. The Collaborative seeks to ensure that pharmacist-provided patient care services in all practice settings are represented in the MU of EHRs. The Collaborative s founding organizations represent pharmacists in all patient care settings and other facets of pharmacy, including pharmacy education and pharmacy education accreditation. The Collaborative s Associate Members represent e-prescribing networks, a standards development organization, and a transaction processing network. The Collaborative was founded by nine pharmacy professional associations representing over 250,000 members and includes six associate members from other pharmacy related organizations. For additional information, visit www.pharmacyhit.org. Finally, the Collaborative reiterates its support of all technological developments and policy actions related to the privacy and security of health data provided that pharmacists are recognized as providers of patient care services and are not limited by any provision exclusion, such as minimum necessary requirements. 4

On behalf of the Pharmacy e-hit Collaborative, thank you again for the opportunity to comment on the request for information regarding Health Care Quality for Exchanges. As the process moves forward, the Collaborative urges you to consider the important role pharmacists play in achieving the clinical and functional objectives to meet meaningful use that results in improvement in patient care and outcomes. For more information, please contact Shelly Spiro, Executive Director, Pharmacy e-hit Collaborative at shelly@pharmacyhit.org. Respectfully submitted, Shelly Spiro Executive Director, Collaborative 5

Shelly Spiro, RPh Executive Director Pharmacy e-health Information Technology Collaborative shelly@pharmacyhit.org Mark N. Brueckl, RPh, MBA Assistant Director, Pharmacy Affairs Academy of Managed Care Pharmacy mbrueckl@amcp.org Mike Rouse B.Pharm (Hons); MPS Assistant Executive Director, Professional Affairs and Director, International Services Accreditation Council for Pharmacy Education (ACPE) mrouse@acpe-accredit.org William Lang, MPH VP Policy and Advocacy American Association of Colleges of Pharmacy wlang@aacp.org C. Edwin Webb, Pharm.D., MPH Associate Executive Director Director, Government and Professional Affairs American College of Clinical Pharmacy ewebb@accp.com Marcie Bough, PharmD Senior Director, Government Affairs American Pharmacists Association mbough@aphanet.org Lynne Batshon Director, Government Affairs American Society of Consultant Pharmacists Lbatshon@ascp.com Christopher J. Topoleski Director, Federal Regulatory Affairs American Society of Health-System Pharmacists ctopoleski@ashp.org Marc J. Ricker CMO IQware Solutions mricker@iqwaresolutions.com Kim Swiger, RPh Vice President, Pharmacy Services Mirixa Corporation kswiger@mirixa.com Ronna B. Hauser, PharmD VP Policy and Regulatory Affairs National Community Pharmacists Association (NCPA) ronna.hauser@ncpanet.org Lynne Gilbertson VP Standards Development National Council for Prescription Drug Programs (NCPDP) lgilbertson@ncpdp.org Stephen Mullenix. RPh Sr VP, Communications & Industry Relations National Council for Prescription Drug Programs (NCPDP) smullenix@ncpdp.org Roger Pinsonneault, R.Ph. Sr. Director, Business Development RelayHealth Pharmacy Roger.Pinsonneault@RelayHealth.com Pharmacy e-health Information Technology Collaborative 401 Holland Lane Suite 702 Alexandria, VA, 22314 www.pharmacye-hit.org 571-312-2904

Michael E. Coughlin President, CEO and CFO ScriptPro mike@scriptpro.com Ken Whittemore, Jr., RPh, MBA Senior VP, Professional & Regulatory Affairs Surescripts ken.whittemore@surescripts.com 7