On September 9, ACCP submitted comments to the Centers for Medicare & Medicaid Services (CMS) related to proposed adjustments to the physician fee schedule (PFS) that would go into effect in calendar year 2025. The PFS is the primary method of payment for Medicare-enrolled health care providers, including payment for professional services of physicians and other health care providers in private practice and incident-to physicians’ services (other than certain drugs covered as incident-to services).

ACCP’s goal in this communication was to urge the integration, coverage, and payment for clinical pharmacists’ medication optimization services within the Medicare program. With an estimated $528 billion a year consumed because of ineffective medication use (equivalent to 16% of total health care spending), the nation’s health care delivery systems consistently fail to deliver the full value that medication therapies can bring to patient outcomes.

To help address this crisis, ACCP is calling for coverage for comprehensive medication management (CMM) services in Medicare. CMM is defined as a direct patient care service provided by clinical pharmacists working as formal members of the patient’s health care team. CMM has been shown through empirical, peer-reviewed studies and everyday practice to significantly improve clinical outcomes and enhance the safety of patients’ medication use.

Positioning Clinical Pharmacists with Their Physician Partners

ACCP’s comments also express concern about a proposed 2.8% reduction in Medicare physician payment and its inevitably negative impact on the collaborative patient care environments in which clinical pharmacists and physicians operate every day. ACCP believes that underpayment to physicians could reduce their interest, willingness, and ability to seek collaboration with other non-physician health care experts, like clinical pharmacists.

ACCP is committed to a longstanding advocacy effort aimed at advancing coverage and payment for comprehensive clinical pharmacy services within Medicare and across other public and commercial payers.

This advocacy initiative is perfectly aligned with ACCP’s Strategic Plan, which calls for the advancement of clinical pharmacists through efforts to achieve recognition of their value by payers, regulators, and the scientific/professional community throughout the world. The Strategic Plan further calls on the College to promote clinical pharmacists by establishing strategic collaborations that increase opportunities for clinical pharmacists to influence research, payment policy, and clinical practice.

Delving deeper into the Strategic Plan, Objective 3.2.2 specifically calls for the development of a joint statement with one or more medical societies citing the value of collaborating with clinical pharmacists to achieve medication optimization.

This strategic focus on advancing collaborative, team-based care and the College’s commitment to fostering strong strategic alliances with its physician colleague organizations is evident in the work of ACCP’s Washington office and their efforts to establish strong partnerships with allied health organizations.

Recently, the American College of Physicians communicated in a letter to Congress their strong support for “arrangements where the pharmacist is part of an integrated, team-based approach to care, such as a patient-centered medical home (PCMH),” further stating:

Congress should invest in the PCMH and other efforts to improve collaboration and team-based care models – consistent with the Joint Principles of the Patient-Centered Medical Home. In a collaborative environment, the pharmacist is a logical member of a team.

Summary

ACCP is fully aware of the American Medical Association’s campaign against what it refers to as “scope creep.” However, the College is fundamentally committed to an advocacy effort that views physicians and other members of the health care team as allies and colleagues. ACCP believes that patients are best served when pharmacists work collaboratively as integrated team members. Similarly, ACCP strives to build advocacy initiatives that replicate this collaborative, team-based approach to problem solving.

Click here to read ACCP’s comments to CMS related to the CY 2025 Physician Fee Schedule.