The Get the Medications Right (GTMRx) Institute has submitted a comment letter in response to the request for information (RFI) issued by the Department of Health & Human Services (HHS). Leaders of the GTMRx Payment and Policy Solutions Workgroup, including Kathy Pham from ACCP and Tom Kraus from ASHP, have provided input on this comment submission that concisely summarizes the successful and innovative models providing comprehensive medication management (CMM) as well as actionable steps to addressing the barriers for implementing CMM models to strengthen primary care.

In the RFI issued by HHS, the agency seeks information on (1) successful models or innovations that help achieve primary health care goals, (2) barriers to implementing successful models or innovations, (3) successful strategies to engage communities, and (4) proposed actions HHS could take. GTMRx has responded to this request by highlighting successful CMM models and identifying payment as the primary barrier to CMM implementation. The letter also includes key payment and policy recommendations extrapolated from its document titled Optimizing Medication Use Through Comprehensive Medication Management in Practice: Strategic Recommendations for Implementing CMM into the Care Team with Sustainable Payment and Practice Structures:

1. Public medical benefit plans (Medicare, Medicaid, VA, marketplace) should preferentially promote and compensate interprofessional care teams through value-based payment models.
2. Under fee-for-service models, physicians should be allowed to bill for complex evaluation and management services provided by members of the interprofessional team working in a collaborative practice with the physician.
3. The AMA Prior Authorization and Utilization Management Reform Principles should be implemented and federal regulation in support of a gold-card approach to eliminating prior authorization requirements for medications should be introduced when clinical pharmacists are providing CMM services as part of an interprofessional team.
4. Federal and state agencies should support training programs to ensure a sufficient workforce of qualified interprofessional team members, including clinical pharmacists, credentialed and privileged to provide CMM services to meet patient and population needs.

For more information about GTMRx’s advocacy efforts and letters along with policy recommendation documents, visit this link on the GTMRx website.