CMS Expands Pharmacist's Role in LTC- Is it Enough?

The Center for Medicare and Medicaid Services (CMS) issued its final ruling in September on the requirements for long term care (LTC) facilities. Emphasizing the importance of pharmacological therapy oversight by the pharmacist, the final ruling requires LTC to provide a pharmacy services section in the resident's medical chart. and invite individual LTC facilities to utilize consultant pharmacy services as part of the healthcare team. While consultant pharmacist routinely (monthly) review resident's medication record and provide recommendations, CMS ruling did not mandate the consultant pharmacist participation in interdisciplinary team (IDT), but left it open to LTC to include or exclude pharmacist from the IDT. Furthermore, LTC facilities are asked (1) to incorporate  quality assurance and performance improvement (QAPI) programs with focus on systems of care, outcomes and quality of life, (2) develop infection control and prevention program that include antibiotic stewardship program and (3) take an active role in developing and implementing a baseline care plan for resident upon admission within 48 hours. All of which can have a significant role for the consultant pharmacist. 

However, when reading the ruling, it appears that most of the exclusions and the comments that CMS received on the role of pharmacist in LTC pivot on considering the pharmacist a health care provider under the Social Security Act, and the cost increase that LTC may incur secondary to the increase of responsibilities delineated to the consultant pharmacist. While the role of pharmacist has been somewhat expanded in the management of psychotropic medications, and infectious disease programs in LTC, the basic foundational role as a member of the health care team seems elusive. 

It is unfortunate that pharmacists continue to be envisioned as "dispenser of pharmaceutical products" and here lies their source of income. While today a large portion of pharmacists are involved in patient care and continue to show their value by increasing positive patient outcomes, some organizations continue to associate the cost of consultant pharmacist services to "products"; albeit hourly rates, or à la carte services, or in the form of indirect cost to state Medicaid and Medicare Part D programs. This subconscious approach to reimbursement undermine the several decades of advancement of the pharmacy profession. Disassociating pharmacy services from products is necessary for any inclusion of pharmacist in the health care team, and ultimately be considered as providers. 

While CMS places an important role on the pharmacy services that are provided to LTC, their remains a need for individual LTC to acknowledge the untapped resources made available to them through the consultant pharmacist, and on the consultant pharmacist to rise to the challenges by shedding the subconscious prejudice when it comes to financial gains.