Matthew M. Murawski,R.Ph.,Ph.D., Associate Professor of Pharmacy Administration; Department of Pharmacy Practice, Purdue University, R.Heine Pharmacy Building Room 502,575 Stadium Mall Drive, West Lafayette, IN
Ernest J Dole, PharmD, PhC, FASHP, BCPS; Clinical Pharmacist III, University of New Mexico Hospitals Pain Consultation and Treatment Center and Clinical Associate Professor, University of New Mexico Health Sciences Center, College of Pharmacy, Department of Pharmacy Practice, Albuquerque, NM
On May 11th, CMS (Centers for Medicare & Medicaid Services) issued a new rule. We think this is perhaps the single most important change in the regulatory status of Pharmacy since Medicaid created third party payment in the 1960s. The new ruling reads as follows: “"We have broadened the concept of 'medical staff' and have allowed hospitals the flexibility to include other practitioners as eligible candidates for the medical staff with hospital privileges to practice in accordance with state law," CMS said in the final rule . The explicit change now allows hospitals to give nonphysician practitioners, such as advanced practice nurses, physician assistants and pharmacists, the power to perform duties that they are trained for and allowed to do within their scope of practice and state law. We feel that stated in the new rule is the ability for pharmacists who work in hospitals, in states with pharmacy acts that allow pharmacist prescribing to prescribe and then bill CMS for provision of those services.
Key provisions are as follows:
1-Role of other practitioners on the Medical Staff: We have broadened the concept of “medical staff” and have allowed hospitals the flexibility to include other practitioners as eligible candidates for the medical staff with hospital privileges to practice in the hospital in accordance with State law. All practitioners will function under the rules of the medical staff. This change will clearly permit hospitals to allow other practitioners (e.g. APRNs, PAs, pharmacists) to perform all functions within their scope of practice. We have required that the medical staff must examine the credentials of all eligible candidates (as defined by the governing body) and then make recommendations for privileges and medical staff membership to the governing body.
2-Orders by other practitioners: We have allowed for drugs and biologicals to be prepared and administered on the orders of practitioners (other than a doctor), in accordance with hospital policy and State law, and have also allowed orders for drugs and biologicals to be documented and signed by practitioners (other than a doctor), in accordance with hospital policy and State law.
3-The potential savings will be achieved through a number of significant regulatory changes. For example, changes to the Medical staff Credentialing & Privliging will allow hospitals to broaden the concept of “medical staff” through the appointment of non-physician practitioners to the medical staff so that they may perform the duties for which they are qualified through training and education and as allowed within their State scope-of-practice laws. For hospitals that choose this option, significant savings might be achieved as non-physician practitioners will enable physicians to more effectively manage their time so that they may focus on the more medically complex patients. In our article, “Advanced-practice pharmacists: Practice characteristics and reimbursement of pharmacists certified for collaborative clinical practice in New Mexico and North Carolina” in AJHP 12/15/2011, this is exactly the point we make. This is further supported by Rear Admiral Scott F. Giberson, RPh, PhC, MPH, US Assistant Surgeon General and chief professional officer of pharmacy at the US Public Health Service in Rockville, Maryland, recent article: Improving Patient and Health System Outcomes Through Advanced Pharmacy Practice. A Report to the US Surgeon General, 2011 .
The new rule concludes with an estimate of savings for each rule change, with the expansion of medical staff being estimated to generate 330 Million the 1st year, and 1.65 Billion over 5 yrs. We are curious that this development has not generated more discussion across the profession, and want to know what you think.
Will Pharmacists gain recognition as medical staff?
If so recognized, will they be able to bill CMS for provision of services?
If pharmacists ARE allowed to bill CMS, will it be as mid-level providers, or will the billing occur at the same level as physicians?
Consider that there is a perfect storm occurring now where:
WHY ARE WE NOT DISCUSSING THIS??