CMS Regulations
Outcomes
100
Does your MTM program "leverage effective MTM to improve safety ...to help address issues of overutilization, and to use the monthly reports on the Part D Patient Safety Analysis website to help identify beneficiaries for who targeted MTM interventions may be beneficial..."?
MTM program administrators should take note of CMS's increased focus on medication adherence, making program additions and enhancements where needed. With regard to high risk medications, MTM program administrators should be updating this element of their clinical program based on guidance published by the American Geriatrics Society on the use of particular medications by elderly beneficiaries.
100
Does your current MTM software include Star Rating-related recommendations, and does it track and report Star Rating-related recommendation outcomes?
"Medication Therapy Management (MTM) program measure (Part D) - Release as a Plan Rating measure would follow production as a 2013 display measure," according to the CY2013 Final Call Letter. MTM program administrators should have reports for their clients to track Beneficiary Level CMR completion and separate Star-based data for the client's MTM program.
200
Does your current MTM program use the Standardized Format for the CMR Action Plan and Summary?
According to CMS regulations, the written summary given to beneficiaries after a CMR must include: CMR Cover Letter, Medication Action Plan, and Personal Medication List.
200
Is your CMR completion rate high enough to provide you with a good Star Rating?
According to the CY2013 Final Call Letter, CMS is considering including "Medication Therapy Management (MTM) - Completion Rate for Comprehensive Medication Review (CMR)" on the 2013 display page. In addition, the CY2013 Final Call Letter "allow(s) individuals to leave Medicare Advantage Plans to enroll in Cost Plans with 5 Stars." A low Star rating could cost Medicare plans money.
300
Does your current MTM program actively engage beneficiaries?
CMS regulations require MTM programs to "use more than one approach when possible to reach all eligible targeted beneficiaries so they are able to receive MTM services and a CMR versus only reaching out via passive offers. Sponsors may increase beneficiary engagement by providing telephonic outreach after mailed outreach."
300
Is your current MTM software able to handle more MTM-eligible lives?
The addition of new disease states will increase the number of members eligible for MTM programs.
400
Is your MTM software prepared to add Alzheimer's disease and End-Stage Renal Disease (ESRD) for targeting?
The CMS Final Call Letter designates these two additional disease states. Clinical programs should be updated accordingly.
400
Are your current resources sufficient to handle all TMRs?
If not, it may be time to consider a solution that assumes the TMR burden to free up clinical staff to conduct the more labor-intensive CMRs.
500
Is your MTM program provider prepared to offer CMRs at least annually to "all beneficiaries enrolled in the MTM program including those in long-term care (LTC) facilities (beginning in 2013)"?
MTM program administrators should be working to increase member and staff awareness. Many, including CSS, are planning to offer Advanced Speech Recognition (ASR) services and an "email reminder" component.
500
Does your current MTM program incorporate all listed 2013 Outcomes Measurements?
MTM programs should be updated continually to meet any and all new CMS requirements, including those listed in the CY2013 Medication Therapy Management (MTM) Program Guidance and Submission Instructions.
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