Update: Pharmacists’ Scope of Practice, CMS, and Physicians

Pharmacists’ scope of practice has been expanding and that growth has been done on the state level. The federal level has been stagnant for quite some time. CMS did make news in June and recently announced a new, voluntary primary care model called “Making Care Primary (MCP)” Model. Sadly, they missed the mark and did not include pharmacists in their overview of the new model.

Here’s the model overview from CMS: “The Making Care Primary (MCP) Model is a 10.5-year multi-payer model with three participation tracks that build upon previous primary care models, such as the Comprehensive Primary Care (CPC), CPC+, and Primary Care First (PCF) models, as well as the Maryland Primary Care Program (MDPCP). MCP aims to improve care for beneficiaries by supporting the delivery of advanced primary care services, which are foundational for a high-performing health system. The MCP Model will provide a pathway for primary care clinicians with varying levels of experience in value-based care to gradually adopt prospective, population-based payments while building infrastructure to improve behavioral health and specialty integration and drive equitable access to care. State Medicaid agencies will commit to designing Medicaid programs to align with MCP in key areas. This model will attempt to strengthen coordination between patients’ primary care clinicians, specialists, social service providers, and behavioral health clinicians, ultimately leading to chronic disease prevention, fewer emergency room visits, and better health outcomes.”

Chronic disease prevention, reducing ER visits, and better health outcomes are in the pharmacist’s wheelhouse and CMS swung and missed by not including us in the “new model”.

Pharmacists’ Scope of Practice – Mixed Support Within The Physician Community

In my experience, individual physicians are more than willing to allow pharmacists (especially board certified and/or residency trained) to prescribe, monitor, and alter medications within defined parameters and under their watch (i.e. collaborative practice agreements). This is especially true of physicians who don’t like managing a particular disease state or disease states where there are constant updates, formulary changes, guideline changes, and new medications to navigate.

American Academy of Family Physicians Stance

In general, AAFP has been supportive of pharmacist collaborative type arrangements. In this position paper, “the AAFP supports arrangements where the pharmacist is part of an integrated, team-based approach to care. The AAFP believes that independent prescription authority for pharmacists will further fragment the American health care system and will undermine the national goals of integrated, accountable care and models such as the PCMH.”

American Medical Association On Pharmacists’ Scope of Practice

The AMA has historically been more hostile towards “scope creep”. It is actually the organization’s “top priority” at the state level. Of all the things going on in the healthcare space that could use improvement, I’d feel a little uncomfortable if stopping what other healthcare professionals could do was my “top” priority as an organization. Maybe that’s just me though. Instead of setting this as the top priority, you’d maybe think encouraging CMS to allow pharmacists to be paid through your clinic (versus the silo of an outside pharmacy) would be more important.

All in all, pharmacists are doing a lot of cool things through collaborative practice agreements despite the unwillingness (or ignorance) of CMS not recognizing our potential to help solve the problems that they seem to care about (ER visits, chronic disease management, etc.). Keep fighting the good fight and trying to educate others about what we can do and where we can help!

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Written By Eric Christianson

July 2, 2023

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