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Community Pharmacy Advocate

Community Pharmacy Advocate is a headliner section of the CPF Website designed to highlight pharmacy news … underscoring health policy and public health issues impacting pharmacy in the political, legislative or regulatory arena. This section does not advocate any specific issue or legislation. This is the role of state and national pharmacy associations which pharmacists should support.  This feature section of the CPF Website highlights in condensed fashion issues impacting public health and pharmacy practice.

CPF is not an advocacy organization nor a professional membership association. CPF is a foundation providing funds/awards to community pharmacists, colleges of pharmacy and health care organizations working with community pharmacies to advance patient care services. These CPF-funded grants are designed to provide other community pharmacists a template on how to duplicate these expanded services in their pharmacy practice.


Medicare Part D initiated the concept of medication therapy management (MTM) associated with well-documented patient care needs involving unintentional inappropriate medication use. The administration for the federal Medicare program is the responsibility of the Centers for Medicare & Medicaid Services (CMS). Medicare Part D  was enacted as part of the Medicare Prescription Drug, Improvement, and Modernization Act (MMA) and went into effect on January 1, 2006.

Within the overall Medicare Act is a section which establishes a “listing” of health care providers under the program.

What has evolved as a noticeable and notable oversight is that pharmacists are not “listed” with what is referenced as “provider status.”

Organized pharmacy is advocating correction of this oversight by CMS. Towards that goal associated with the ongoing work of the national professional associations is a grassroots national petition effort launched by Pharmacist Sandra Leal.

Pharmacists are encouraged to visit the website and consider adding their collective voice to this petition to the President of United States  (website address is) -




Some believe that collaborative practice agreements are necessary in state pharmacy practice acts in order to “collaborate.” Others believe this cooperation or collaboration can occur between willing and authorized health care providers on its own accord, much like in hospitals through a policy & procedure referenced as “standing orders.”

In other instances some state pharmacy practice acts have become so littered with details that scope of practice matters and definitions can often be “limited” by the very expansion authorization.

Regardless of your position on this very important discussion topic within the pharmacy profession  - and between health care professionals such as physician and advance practice nurse groups, the following is for consideration as so-called “model legislation” for a state pharmacy practice act implemented by regulation or legislation” –

DRAFT: Suggested Comprehensive Medication Management Services  (CMMS)  Legislation-

Provided CPF by noted healthcare consultant Terry McInnis MD MPH- President Blue Thorn, Inc-  tamcinnis@bluethorninc.com.  This should not be considered legal advice and must be considered in the context of existing state legislation.)


Comprehensive Medication Management Services (CMMS).

(a) Medical assistance shall cover CMMS for a recipient taking four or more prescriptions to treat or prevent two or more chronic medical conditions, or for a recipient with a drug therapy problem that is identified or prior authorized by the Secretary that has resulted or is likely to result in significant nondrug program costs, or as requested by the physician or other licensed prescriber.  For purposes of this subdivision “Comprehensive Medication Management Services " means the provision of the following services utilizing the professional practice of pharmaceutical care by a licensed pharmacist. The goal of CMMS is to improve quality outcomes for patients and lower overall healthcare costs (including emergency room, hospital, provider, and other non-pharmacy costs, in addition to drug product costs) by optimizing appropriate medication use linked directly to achievement of the clinical goals of therapy.  CMMS shall include the following key elements:

(1) performing or obtaining necessary assessments of the patient's health status including understanding  the patient’s personal medication experience/history and preferences/beliefs  while  identifying and recording  actual use patterns of all medications including OTCs, bioactive supplements, and prescribed medications;
(2) documenting all the patient’s medication, current clinical status, and clinical goals of therapy  for each identified chronic condition or preventive therapy in collaboration with prescribers as necessary, for example, current patient blood pressure and prescriber goal of blood pressure or clinical guideline goals as appropriate.  Patient goals may also be documented where appropriate;
(3) assessing each medication, in the following order, for appropriateness, effectiveness, safety (including drug interactions), and adherence; focusing on achievement of the clinical goals for each therapy.  Additional medications, deletions of medications, and changes in drugs/dosages needed to meet these clinical goals shall be suggested to prescribers and patients;
(4)  identifying all drug therapy problems, i.e., the gap between current therapy and that needed to achieve optimal clinical outcomes;
(5)  developing a comprehensive medication care plan addressing recommended steps including therapeutic changes needed to achieve optimal outcomes aligned with evidenced based practice and recognized standards of care; (6) documenting the care delivered and assuring the patient agrees with and understands the medication care plan which is communicated to the prescriber/provider for his/her consent/support;
(7) follow-up evaluations with the patient to determine effects of changes, reassess actual outcomes, and recommend further therapeutic changes to achieve desired clinical goals/outcomes; and
(8)  coordinating and integrating CMMS within the broader health care management services being provided to the patient in coordinated care delivery systems such as the patient-centered medical home and accountable care organizations by assuring that patients and prescribers/care coordinators are aware of and receive the recommendations in the medication care plan.

Nothing in this subdivision shall be construed to expand or modify the scope of practice of the pharmacist as defined in the (insert state Pharmacy Practice Act).


 (b) To be eligible for reimbursement for services under this subdivision, a pharmacist must meet the following requirements:

(1) have a valid license in the state;

(2) have graduated from an accredited college of pharmacy or completed a structured and comprehensive education program approved by the Board of Pharmacy and the American Council of Pharmaceutical Education for the provision and documentation of pharmaceutical care management services that has both clinical and didactic elements;

(3) be practicing in an ambulatory care setting as part of a multidisciplinary team or have developed a structured patient care process that is offered in a private or semiprivate patient care area that is separate from the commercial business that also occurs in the setting, or in home settings or telephonically in direct communication between the pharmacist and patient so long as the quality of the interaction, clinical results and economic results are documented to be equivalent to face to face interactions, if the service is ordered by the provider-directed care coordination team; and

(4) be appropriately trained and make use of an electronic patient record system that: (i)  meets state standards and meaningful use requirements; (ii) is able to adequately document and share medication care plans both for patient use and recommendations to prescribers;  (iii) can generate quality reports to document drug therapy problem identification and resolution with changes in clinical goal achievement from baseline; (iv) can substantiate all of the requirements of section (a) for the purposes of documentation of interactions with patients and prescribers;  and (v) adequately captures the work performed to map to the appropriate complexity levels for billing.


(c) For purposes of reimbursement for CMMS, existing CPT codes with defined levels of complexity and drug therapy problems shall be utilized.

(d) The Secretary shall evaluate the effect of CMMS on quality of care, patient outcomes and program costs, and shall include a description of any savings generated in the medical assistance and general assistance medical care programs that can be attributable to this coverage, including the effect on emergency room, other provider visits,  and hospital costs. Patient and prescriber surveys may also be used to assess acceptance of the services and perceived value added.  The Secretary may contract with a vendor or an academic institution that has expertise in evaluating health care outcomes for the purpose of completing the evaluation.


The following websites provide additional information and details of community pharmacy advocate activities –

  • American Pharmacists Association (APhA) Visit

  • National Association of Chain Drug Stores (NACDS) Visit

  • National Community Pharmacists Association (NCPA) Visit


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