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Legislative Issues
Washington State Legislation
Federal Legislation
Contact your Legislators!
NEWS
US Senate and House Pass Bill Extending Medicare DME Accreditation Deadline for Pharmacies
Oct 5, 2009 - The US Senate and House of Representatives passed a bill extending Medicare DME Accreditation deadline for pharmacies. Now it must be signed by the President. The extension gives pharmacies until January 1, 2010 to obtain accreditation, EXCEPT we believe that Congress will pass some form of DME accreditation modification for pharmacies before that time. That could obviate the need for pharmacies to meet the existing accreditation standards, which many pharmacies have found to be costly and burdensome.
Contact Key Committee Members TODAY about Average Manufacturers Price (AMP)!
House Energy and Commerce Committee Members
Representative Jay Inslee- Chief of Staff Brian Bonlender at (202) 225-6311 Email:www.house.gov/inslee/contact/email.html Website: www.house.gov/inslee
House Ways & Means Committee Members
Representative Jim McDermott - Chief of Staff Mike DeCesareat (202) 225-3106 Email:www.house.gov/mcdermott/contact.html Website: www.house.gov/mcdermott
Representative Dave Reichert at (202) 225-7761 Chief of Staff Chris Miller Website: http://reichert.house.gov/
Senate Finance Committee Members
Senator Maria Cantwell -Chief of Staff Katharine Lister (202) 224-3441 Email: maria_cantwell@cantwell.senate.gov Website: cantwell.senate.gov
Below are AMP talking points you can use:
-We very much appreciate the fact that the House draft includes reforms to the AMP-based reimbursement system for Medicaid generic drugs.
-However, we are concerned that setting generic reimbursement at 130% of the weighted average AMP, combined with the low dispensing fees paid by states, will in total still significantly underpay pharmacies for dispensing low-cost generic drugs in the Medicaid program.
-Significantly reduced access for Medicaid recipients to prescription services will result from inadequate Medicaid pharmacy reimbursement.
-Please consider a higher Federal Upper Limit reimbursement rate for community pharmacies.
Contact Key Committee Members TODAY about Durable Medical Eqipment (DME) Accreditation!
House Energy and Commerce Committee Members
Representative Jay Inslee- Chief of Staff Brian Bonlender at (202) 225-6311 Email:www.house.gov/inslee/contact/email.html Website: www.house.gov/inslee
House Ways & Means Committee Members
Representative Jim McDermott - Chief of Staff Mike DeCesareat (202) 225-3106 Email:www.house.gov/mcdermott/contact.html Website: www.house.gov/mcdermott
Representative Dave Reichert- Chief of Staff: Chris Miller at (202) 225-7761 Website: http://reichert.house.gov/
Senate Finance Committee Members
Senator Maria Cantwell -Chief of Staff Katharine Lister (202) 224-3441 Email: maria_cantwell@cantwell.senate.gov Website: cantwell.senate.gov
Below are DME Accreditation talking points you can use:
-Medicare beneficiaries’ access to diabetes testing supplies – such as blood glucose test strips and lancets – will be reduced if modifications are not made to the requirements that community pharmacies acquire DME "accreditation" and obtain surety bonds.
-These provisions combined – both set to go into effect on October 1st - will significantly reduce by thousands the number of pharmacies that will be able to provide diabetes testing supplies to Medicare beneficiaries.
-This will negatively impact the ability of Medicare beneficiaries to manage their diabetes, and could increase Medicare costs for hospitalizations.
-Please exempt pharmacies from the accreditation process if they are distributing non-complex DME (i.e. diabetes test strips, canes, crutches).
Contact Your Senators TODAY about Supporting Medication the Senate HELP Legislation !
Section 213 of the Affordable Health Choices Act provides grants to implement Medication Management Services (MTM) in the Treatment of Chronic Disease. This means pharmacists could get reimbursed for the many services we provide our patients. Call your Senator to urge their support today!
The issue:
More patients could benefit from the medication therapy management (MTM) services provided by pharmacists, especially those with chronic medical conditions. Many pharmacists provide MTM services under Medicare Part D, and we support efforts to expand and improve those services. We support the MTM grant program established in Section 213 because it will test new and innovative ways for pharmacists to deliver these MTM. The program will test how MTM delivery and patient outcomes are improved when pharmacists have access to more specific patient information delivered by an interoperable health care network. It also allows pharmacists to play a larger role in reducing improper medication use, which has been estimated to cost $177 billion in treatment costs annually.
The Action:
Contact Senator Murray and Senator Cantwell today and ask them to support Medication Therapy Management (MTM) programs.
Senator Maria Cantwell on the Senate Finance Committee (202) 224-3441 Email: maria_cantwell@cantwell.senate.gov Website: cantwell.senate.gov
Senator Patty Murray on the HELP Committee (202) 224-2621 Email: http://murray.senate.gov/contact/ Website:http://murray.senate.gov/
A staff member will pick up the phone. Tell them your name, pharmacy and number of patients you serve each month.
Here are a few talking points to use:
- Please support Section 213 of the Affordable Health Choices Act. This section provides for an expansion of Medication Therapy Management, or MTM.
- The MTM services offered by pharmacists promote health and save money by ensuring patients are taking the correct medications and are taking them properly.
- MTM also reduces improper medication use which is estimated to cost $177 Billion each year.
- Please support MTM programs like those in Section 213 of the Affordable Health Choices Act. Thank you.
Send a Letter on Community Pharmacy Recommendations for Health Care Reform Model Letter
Support Materials
APhA Leave Behind Document link
Pharmacy Principles for Healthcare Reform PDF
Senate HELP Legislation BillPharmacy Support Press Release
Protecting US Citizens from Inappropriate Medication Use White Paper- EXCELLENT
2010 Washington State Legislative Session
LRAC is your front line voice representing pharmacy and your issues in Olympia with the Washington Legislature, State Agencies and the Governor's office. LRAC is in Olympia working for you full time year round. In tough times like these, it is even more important to stay involved.The Legislative and Regulatory Affairs Council (LRAC) is an essential protection for our profession who works closely with the Washington State Pharmacy Association and keypharmacy stakeholders to form a great partnership and we must keep it going.Please, if you are not an LRAC member, join today. Individual memberships are $50 and pharmacy memberships are only $180 per location. You will be kept current on the legislative issues via the LRAC e-mail list and your voice will be heard! Your LRAC membership dollars ensure that pharmacy has a full-time lobbyist in Olympia representing our needs. Join LRAC online today!
For more information contact:
Dedi Hitchens, Director of Government Affairs
Washington State Pharmacy Legislative & Regulatory Affairs Council
dhitchens@wsparx.org
Federal Legislation
APhA Government Affairs
APhA Legislative Update September 20, 2009
Report by Sonnenschein Nath & Rosenthal LLP
Congress
Both the House and Senate will resume legislative business next week.
Health Care Reform: On Wednesday, Senate Finance Committee Chairman Max Baucus (D-MT) officially released his Chairman’s Mark on health care reform. The America’s Healthy Future Act of 2009 includes public cooperatives instead of a public health insurance option, an individual mandate to obtain health insurance coverage, a newly established Medicare Commission with authority to implement Medicare payment changes, and an expansion of Medicaid. The Congressional Budget Office estimates that the bill would cost $774 billion over ten years, but would be fully-offset (i.e., budget-neutral).
Many policymakers believe that Baucus’ proposal is the last possible option to pass bipartisan health care reform legislation. If Baucus’ legislation does not receive bipartisan support in either the Finance Committee or on the floor of the Senate, Senate Democratic Leadership may move health care reform legislation using the budget reconciliation process. Although some Democrats on the Finance Committee expressed initial opposition to the Baucus proposal, Democratic leadership is confident that these concerns will be addressed during the Committee’s markup and the legislation will ultimately pass the Committee.
In the House, Democratic members of the Energy and Commerce Committee met this week in anticipation of further markups next week. Committee leadership met with Blue Dog Democrats serving on the Committee and it is expected that Blue Dogs will not stall a markup, should it occur next week. We do not expect the markup to take a significant amount of time or address highly-controversial issues.
Final health care reform legislation will not be considered by the House of Representatives until the Senate has made substantial progress in passing a bill. The Speaker does not want to make her Members walk a “political tight rope” without first seeing legitimate progress in the Senate, however, she continues to affirm her commitment to including a public health insurance option in the final House bill. Before the House can consider a bill, the Rules Committee will have to combine legislation from the three relevant House Committees and set the rules for the floor debate. House Leadership will have to reach a deal that will address the concerns of both moderate and progressive Democrats.
Senate Finance Committee -- The Senate Finance Committee will begin its markup of the Chairman’s Mark on Tuesday, September 22. Although the markup is expected to be partisan and lengthy (the Committee may consider several hundred amendments), Chairman Baucus expects the process to conclude by September 28. Although Senators were pleased to see Baucus release the Chairman’s Mark after several months of negotiations, the Mark did not receive robust support on either side of the aisle. Many Senate Democrats openly voiced their opposition to the Mark. Senator Jay Rockefeller (D-WV), a member of the Senate Finance Committee, said that he would not support the legislation in its current form, and plans to offer dozens of amendments at the Committee markup, including a public health insurance option.
Some of the provisions included in the Chairman’s Mark include:
• Creation of a “cooperative” alternative to the public health insurance plan.
• Insurance market reforms that would ban insurers from denying coverage for pre-existing conditions, caps out of pocket expenses, and includes prevention and wellness provisions.
• Establishes an independent Medicare Commission that would have the authority to implement Medicare payment changes, unless objected to by Congress.
• Expansion of the Medicaid program to cover all people earning up to 133% of the federal poverty level (FPL). The federal government would provide additional funding to the states for covering this expansion.
• An individual mandate to obtain health insurance coverage, coupled with sliding-scale subsidies for people earning between 133% to 300% of FPL.
• Some protections will be provided for individuals with incomes from 300% to 400% of FPL - generally, they will not be required to pay more than 13% of their annual income in premiums.
• Out-of-pocket expenses for health care would be limited to $11,190 for a family and $5,950 for an individual.
• There is no employer mandate, but instead a “free rider” proposal that would not expressly require employers to provide insurance. Employers that do not offer health insurance will be required to compensate the government for any subsidies provided to uninsured employees.
Concerns of other Senate Finance Committee Democrats will also have to be addressed to pass the legislation out of the Committee. To this end, the Senate Democratic Caucus met on Thursday to negotiate the procedure for the markup and how two Finance and HELP Committee health care reform bills will be merged into one. The most controversial issue that will have to be addressed is the public health insurance option. Because Baucus remains committed to bipartisan support, his Mark did not include a public option. Rather, it included the creation of public health care cooperatives. Many Democrats argue that cooperatives would not bring about strong enough competition in the marketplace and that a public health insurance option is vital to health care reform. Other highly debated areas that will likely be addressed during the markup include the overall cost of health care reform, Medicare Advantage, individual and employer mandates, affordability credits, and new taxes (revenue raisers).
Senate HELP Committee -- Senator Tom Harkin (D-IA) was recently appointed to serve as Chairman of the Senate HELP Committee, succeeding the late Senator Ted Kennedy (D-MA). Harkin will be a major player in the weeks and months to come as he works with Democratic Leadership to combine legislation from the Senate HELP and Finance Committees. Even though the Senate has made headway by passing a bill out of the Senate HELP Committee, the Committee has little jurisdiction over key areas of health care reform (e.g., the Medicare program and taxes) and several issues were not resolved by the HELP Committee’s actions.
House Tri-Committees -- The three House Committees with jurisdiction over health care reform are the Ways and Means Committee, Energy and Commerce Committee, and Education and Labor Committee. As you know, before adjourning for August recess, the three Committees completed markups of H.R. 3200, America’s Affordable Health Choices Act of 2009.
Democratic Leaders will need to balance the views of the conservative Blue Dogs with the larger progressive majority of the Democratic caucus. This process is likely to test the mettle of the Blue Dogs and their willingness to vote against the bill in sufficient numbers to hold up House floor consideration.
House Leaders want to present a bill to the President before Thanksgiving. However, this timeline may prove unlikely as more Members are growing concerned with the Administration’s stance with regard to the public health insurance option. Specifically, House Speaker Nancy Pelosi (D-CA) believes this is a critical issue and she may not bring a bill to the floor of the House that does not include the public health insurance option. As noted above, it is also expected that the House will not consider a bill until the Senate moves forward with consideration of its bill.
Health Care Reform Calendar -- It is unlikely that the House or Senate will vote on a health care reform bill until mid-October at the earliest. President Obama has extended his October 1 deadline and wants Congress to put a bill on his desk before year’s end. An updated calendar of the Congressional health care reform agenda is available at the following link: http://www.sonnenschein.com/docs/HCReformCalendar09.pdf.
Next Week’s Hearings:
• The Senate Finance Committee will begin its markup on Tuesday, September 22. This markup may last for several days.
• On Wednesday, September 23, the House Energy and Commerce Committee plans to continue its markup.
White House
Since his address to Congress, President Obama has continued his push to regain momentum for enacting comprehensive health care reform. After a difficult and contentious Summer for policymakers and the Administration, the president has focused on a public campaign to build on the positive response from his address to Congress. In this regard, Obama will again hit the airwaves and news programs over the weekend to counteract opposition to his health care reform plan.
Centers for Medicare and Medicaid Services (CMS)
President Obama has not yet nominated a CMS Administrator. It is anticipated that President Obama will not nominate an Administrator until health care reform legislation has been considered by Congress. Despite the absence of political leadership at CMS, the agency continues to move forward with its mission. On Tuesday, CMS released the end-stage renal disease (ESRD) proposed rule, which implements a new fully-bundled payment system for ESRD services. Directed by the Medicare Improvements for Patients and Providers Act of 2008, the new ESRD payment system goes into effect January 1, 2011 and represents a significant change to the way the Medicare program pays for treating dialysis patients.
We will continue to keep you posted of important developments in Washington.
APhA Medication Use Document: To assist you in your advocacy efforts, APhA has developed document explaining: our nation's medication use problem; information on APhA Foundation programs that have worked in assisting patients in managing their medications; APhA's recommendations on how to reform the delivery system to achieve quality and cost goals; and quotes from key organizations on the importance of pharmacists and medication management. View APhA's Medication Use Document.>>
Kristina E. Lunner
Vice President, Government Affairs
American Pharmacists Association
2215 Constitution Avenue, NW
Washington DC 20037-2985
800/237-APhA (2742)
202/429-7507
202/497-5953 (c)
202/429-6300 (f)
klunner@aphanet.org
www.pharmacist.com
NCPA Government Affairs
Government Affairs Update - Week Ending October 3rd, 2009
Health Care Reform
Reports are that the House will be atempting to pass a health care reform bill within the next two weeks. The Senate Finance Committee finished marking up its bill this past week, and Senate leaders will attempt to merge the Senate Finance bill with the bill that was reported out of the Senate HELP Committee in July. Conventional thinking is that a health care reform bill will be passed by Congress sometime in December.
With respect to community pharmacy priorities in the health care reform bills, NCPA continues to do the following:
• Indicate that our top priorities for health reform is to permanently fix the AMP Medicaid pharmacy reimbursement system; include a exemption for pharmacies from the current DME accreditation requirements; include a requirement that PBMs that contract with health plans that operate in the new health insurance exchange be transparent to the plan sponsors; promote the clinical role of the pharmacist; and assure that any drug benefit that may be part of a government negotiated plan (such as a public plan or a co-op) is administered by a PBA rather than a PBM and does not include incentives to use mail order.
NCPA staff members continue to meet with Senate leadership staff to discuss our priorities for health care reform. At this point, we will be asking NCPA members to communicate with Senators to provide them with our priorities for health care reform.
PBM Transparency
NCPA worked very closely with Senator Maria Cantwell (D-WA), a Member of the Senate Finance Committee, to successfully include PBM transparency language in the Senate Finance bill that will be reported out of Committee next week. The language mirrors the provision that was included in the House Energy and Commerce Committee’s health care reform bill. The language would require that plans confidentially provide information to the plan sponsor on aggregate manufacturer rebates that are passed through to the plan sponsors; aggregate difference between amount the plan paid the PBM and the amount the PBM paid the pharmacy; and generic dispensing and substitution rates in retail and mail order pharmacy. NCPA is working with Senator Cantwell’s office and other Senate offices to assure that the language remains in the combined Senate bill.
Reform of FEHBP Drug Benefit
NCPA was the only pharmacy group invited to participate in a Congressional workshop that focused on how to reform the Federal Employees Health Benefits Program (FEHBP) pharmacy benefits program. Over 9 million employees and retirees use the program, the largest of which is the BC/BS standard option program. This program uses CVS/Caremark as its PBM. Congress appears to believe that there is a lack of transparency in how the FEHBP program operates, and that FEHBP is paying higher manufacturers’ prices for prescription drugs than other Federal programs. NCPA is working with the Congressional oversight Committee to explain how we think the program can be restructured so that it is better for taxpayers and patients.
Federal legislation of DXM Sales
NCPA staff met this week with Senator Durbin’s (D-IL) staff to discuss a bill that he has introduced that would require retailers that sell OTC products that contain dextromethorphan (DXM) to check the identification of purchasers to make sure they are 18 years of age or older. The bill would not require log books to track these sales, nor are there quantity limits. However, this bill would create the first Federal oversight for sales of these products. We are providing feedback to his office on community pharmacy concerns.
Update on Implementation of Possible DME Accreditation Deadline Delay
This is the update on DMEPOS accreditation and the continued ability for pharmacies to bill for DMEPOS given the possible extension by Congress of the October 1, 2009 accreditation deadline. The extension would give pharmacies until January 1, 2010 to obtain accreditation, EXCEPT we believe that Congress will pass some form of DME accreditation modification for pharmacies before that time. That could obviate the need for pharmacies to meet the existing accreditation standards, which many pharmacies have found to be costly and burdensome.
The House has passed the deadline extension, but the Senate has not yet acted. They are likely to act next week. Because the extension is likely to pass next week, CMS has advised us that pharmacies, under certain circumstances, can continue to bill for DMEPOS. In this e-mail we want to try and describe the situation as we know it.
• Those pharmacies that have obtained accreditation and a surety bond, can continue to provide Medicare Part B drugs, vaccinations and DMEPOS.
• If a pharmacy has voluntarily terminated from the Medicare Part B program OR has “stepped down” on their 855S forms (that is, indicating that the pharmacy would be providing only Part B drugs BUT not DMEPOS) and the National Supplier Clearinghouse (NSC) has processed your application, then you are unable to bill for DMEPOS even if the extension passes next week. A pharmacy should receive a confirmation letter from NSC regarding their change in status. If your “stepped down” application has been processed, UNLESS you modify your 855S again to indicate that you are going to also be dispensing Medicare DMEPOS in addition to Part B drugs, you cannot provide DMEPOS even if the extension passed. Processing these applications could take some time, so you would be able to bill again for DMEPOS, but it may take several weeks for CMS/NSC to process the “step up” application.
• If you have “stepped down” and are waiting for accreditation, CMS has said that your billing privileges exist as of the date on the accreditation certificate.
• If a pharmacy has voluntarily terminated from Medicare Part B OR has “stepped down” on their 855S form and NSC HAS NOT processed your application, you can continue to bill for DMEPOS and Part B drugs. NSC will not process that application. The key is KNOWING whether the application has been processed. NCPA has secured a commitment from CMS that they will ask the NSC to NOT process and further pharmacy applications that request a “step” down or voluntarily termination from the program. Therefore, if you submitted either form within the last few days, it is not likely that it has been processed. If you application has not been processed, CMS has indicated that you can continue to bill for Part B drugs and DMEPOS – assuming you have a surety bond. If you WANT NSC to process the application to step down or voluntarily terminate, then CMS is going to ask pharmacies to send a letter to the NSC, asking that they process the application. Pharmacies can also call the NSC to see if their application has been processed, but it may take some time to get through given the number of calls going into the NSC.
• AS ALWAYS, YOU MUST OBTAIN A SURETY BOND TO CONTINUE TO BILL MEDICARE PART B FOR EITHER DRUGS/VACCINATIONS OR DMEPOS!!! You only need a surety bond to bill for Medicare Part B drugs/vaccinations if you are not billing for DMEPOS. CMS has said that they will give SOME flexibility to pharmacies on getting the surety bonds in October – days, not weeks. So, get it in as soon as you can!!!
We are hopeful that the Senate will pass this extension next week. One caution – if the Senate does not for some reason pass the extension, then existing law remains. Pharmacies need to be accredited to sell DMEPOS. However, we are optimistic that it will pass.
Other Regulatory Issues
• FDA Regulation of Tobacco: Submitted comments to FDA on the regulation of tobacco. Comments focused on the need for increased federal and state funding for smoking cessation and the integral role of the pharmacist in smoking cessation efforts, including the opportunity to incorporate cessation programs into MTM programs.
• Clinical Pharmacy Services in 340B Clinics: NCPA attended the briefing on the HRSA PSPC Public/Private Alliance and also learned about results from teams who participated in the first year of the program. Currently there are over 100 teams participating in the second cohort of PSPC, including several independent community pharmacies. Each team includes a HRSA funded entity and provider of clinical pharmacy services (some pharmacies are onsite at a community health center for example, while other teams work with pharmacies in the community to provide services). The goal of the teams is to incorporate clinical pharmacy services into their health systems and each team varies in their composition but all focus on a multidisciplinary, integrated health care team approach to provide patient centered care for their high risk patients. Of note, the Collaborative is being looked at by multiple parties as an example of coordinated care being called for in the health care reform bills. The PSPC Public/Private Alliance is seeking to incorporate as a 501(c)(3) in order to raise funds for the initiative. .
• Part D and “Non-Matched FDA Drugs”: NCPA participated on a call with CMS regarding the Non matched NDC list which will be released any day and will be used by CMS to determine product eligibility in the Part D program. NCPA brought up several concerns we have with the list, including a lack of CMS outreach to mfg alerting them to need to list their products with FDA and a lack of clear guidance to plans regarding timing of system updates and POS edits to pharmacies. We also relayed our concerns with pharmacies being subject to recoupment (a distinct possibility). We will have a better idea of the number of products affected when the list is released and will stay in constant contact with CMS regarding a potential transition period. Of note, CMS will not add to the list for the 2010 plan year, only delete products that have verified listing with the FDA.
This document produced with the important input of the NCPA Government Affairs team. Please contact NCPA with any questions: John M. Coster, Ph.D., R.Ph., Senior Vice President, Government Affairs, National Community Pharmacists Association, 703-600-1184, 517-214-3936 – cell, John.coster@ncpanet.org
ASHP Government Affairs
Restore Funding for PGY2 Residency Programs -
ASHP Executive Vice President and CEO Henri R. Manasse, Jr., Ph.D., Sc.D., this week urged members of the Senate Finance Committee to restore funding for Post Graduate Year 2 (PGY2) specialized pharmacy residency programs in health care reform legislation. ASHP’s grassroots advocacy team is also working with members in Montana and Iowa in targeted outreach to Senators Max Baucus (D-Mont.) and Charles Grassley (R-Iowa), the chair and ranking minority member of the Senate Finance committee, on the issue. For more information on ASHP’s advocacy to restore PGY2 residency funding contact Joe Hill in the ASHP Government Affairs Division at gad@ashp.org.
Join ASHP's Health Care Reform Efforts! Policy makers have been hard at work drafting health care reform legislation for several months and soon legislation will be introduced that will significantly alter the delivery of health care in our country. ASHP has met with White House staff, officials of the Department of Health and Human Services, and key congressional staff as they develop legislative proposals. Now it is time for them to hear from you. Take time today to let your congressional representatives know the important medication-related patient care services that pharmacists provide on interdisciplinary health care teams. Click on "Take Action" to send an e-mail to your legislators. If you have any questions, please contact us at (301) 664-8692 or via e-mail at gad@ashp.org
Because the extension is likely to pass this week, CMS has advised us that pharmacies, under certain circumstances, can continue to bill for DMEPOS. In this e-mail we want to try and describe the situation as we know it.
• Those pharmacies that have obtained accreditation and a surety bond, can continue to provide Medicare Part B drugs, vaccinations and DMEPOS.
• If a pharmacy has voluntarily terminated from the Medicare Part B program OR has “stepped down” on their 855S forms (that is, indicating that the pharmacy would be providing only Part B drugs BUT not DMEPOS) and the National Supplier Clearinghouse (NSC) has processed your application, then you are unable to bill for DMEPOS even if the extension passes next week. A pharmacy should receive a confirmation letter from NSC regarding their change in status. If your “stepped down” application has been processed, UNLESS you modify your 855S again to indicate that you are going to also be dispensing Medicare DMEPOS in addition to Part B drugs, you cannot provide DMEPOS even if the extension passed. Processing these applications could take some time, so you would be able to bill again for DMEPOS, but it may take several weeks for CMS/NSC to process the “step up” application.
• If you have “stepped down” and are waiting for accreditation, CMS has said that your billing privileges exist as of the date on the accreditation certificate.
• If a pharmacy has voluntarily terminated from Medicare Part B OR has “stepped down” on their 855S form and NSC HAS NOT processed your application, you can continue to bill for DMEPOS and Part B drugs. NSC will not process that application. The key is KNOWING whether the application has been processed. NCPA has secured a commitment from CMS that they will ask the NSC to NOT process and further pharmacy applications that request a “step” down or voluntarily termination from the program. Therefore, if you submitted either form within the last few days, it is not likely that it has been processed. If you application has not been processed, CMS has indicated that you can continue to bill for Part B drugs and DMEPOS – assuming you have a surety bond. If you WANT NSC to process the application to step down or voluntarily terminate, then CMS is going to ask pharmacies to send a letter to the NSC, asking that they process the application. Pharmacies can also call the NSC to see if their application has been processed, but it may take some time to get through given the number of calls going into the NSC.
• AS ALWAYS, YOU MUST OBTAIN A SURETY BOND TO CONTINUE TO BILL MEDICARE PART B FOR EITHER DRUGS/VACCINATIONS OR DMEPOS!!! You only need a surety bond to bill for Medicare Part B drugs/vaccinations if you are not billing for DMEPOS. CMS has said that they will give SOME flexibility to pharmacies on getting the surety bonds in October – days, not weeks. So, get it in as soon as you can!!!
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