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Long Term Care Pharmacy Alliance Concerned with Proposed CMS Rule; New Study Confirms LTCPA Position
Date:1/12/2011

ge of waste would save only $125 million annually and cost over $900 million in additional dispensing fees.  This is in stark contrast to the $712.5 million in annual savings estimated by the Congressional Budget Office in their scoring of the short-cycling provision.
  • The tradeoff between reduced waste associated with unused medication and increased pharmacy operating costs due to more frequent medication dispensing only becomes favorable to the taxpayer for prescriptions with original dispensed value of over $400.

  • In its comments, LTCPA stated that CMS's approach on short-cycle dispensing is contrary to Congress' intent that Section 3310 of the Patient Protection and Affordable Care Act result in savings to Medicare Part D. "We believe that it was Congress' intent to decrease costs associated with unused medications for Part D residents in LTC facilities.  Implementing short cycle dispensing for long term care patients with an average length of stay of 835 days who are primarily taking maintenance medications does not meet this financial goal. While we applaud CMS's initial proposal to short cycle traditionally more expensive brand products, we believe that this limitation isn't narrow enough. Our data clearly shows that there is a prescription value threshold of $400 that must be met in order to achieve any cost savings," continued Bill Daniel.

    In the proposed regulations, CMS calls for data collection by Part D plans in order to study the efficiencies of various dispensing methodologies and to estimate the cost of unused drugs and possible savings.  As CMS has identified their lack of data on unused Part D drugs in this population, LTCPA recommends that before drafting any final regulations CMS conduct a study to determine the causes, frequency and cost of unused medications and also consider alternatives to 7-day dispensing cycles.

    To read LTCPA's full comments or to view the study,

    SOURCE Long Term Care Pharmacy Alliance
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