Last week, the Ohio Department of Medicaid (ODM) released their long-awaited proposal for a revamped reimbursement model for pharmacies. The proposed rule changes will impact reimbursement for covered drugs and durable medical equipment (DME) within the Medicaid fee-for-service program. These are major, substantive changes, each with their own layers of potential issues for pharmacies, so we ask that you please review, and give us your feedback as soon as possible.
The Department plans to file the rules on January 13, 2017, and the initial comment period is open until December 23, 2016. While we will have additional opportunities to provide comment, we highly recommend submitting your comments by December 23. To submit comments on draft rules please send an email to BIA@Medicaid.Ohio.gov and CSIPublicComments@governor.ohio.gov. Comments on draft rules are public record, please do not submit any protected health information.
Also, as OPA plans to submit comments from the association as a whole, it is important that if you have issues you would like to call our attention to, we would need your feedback by Wednesday, December 21. Please send that feedback to email@example.com. We realize that this a very quick turnaround, but we're operating on the state's timeline; not ours.
To review the rule package and the reimbursement changes, click here.
Here are some initial items for you to note:
Please keep in mind; there is more to the rule package than what is listed above, so it is important that if your practice may be impacted by changes in the Ohio Department of Medicaid's fee-for-service program (at this time, these changes do will not impact Medicaid Managed Care Organizations), it is important that you and your team review these proposed rule changes. We need your feedback by Wednesday if you would like OPA to know about your issues in advance of us submitting written comments. Send to firstname.lastname@example.org. We also highly recommend submitting your own comments independently by Friday, December 23. To submit comments on draft rules please send an email to BIA@Medicaid.Ohio.gov and CSIPublicComments@governor.ohio.gov. Comments on draft rules are public record, please do not submit any protected health information.
As OPA has informed you leading up to this point, this is the follow-up to the ODM survey of Ohio pharmacies for the cost of dispensing medications to Ohio Medicaid beneficiaries. The Centers for Medicare & Medicaid Services (CMS) published the federal Covered Outpatient Drugs Final Rule (CMS-2345-FC) on January 21, 2016. To comply with the Final Rule, ODM contracted with Mercer Government Human Services Consulting (Mercer), a part of Mercer Health & Benefits LLC, to conduct a professional dispensing fee (PDF) survey to better understand and approximate the current cost of dispensing prescription medications to Ohio Medicaid beneficiaries. That survey and its analysis are what ODM is using to gain an overall understanding and evaluation of its pharmacy reimbursement components and the impact to the cost of dispensing prescription medications in Ohio.
The ODM collaborated with Mercer to develop the PDF survey for pharmacy providers in Ohio. As a reminder, participation in the survey was mandatory in accordance with the provisions in the Ohio Revised Code (ORC) 5164.752.
The results of that survey have been published and can be accessed here. ODM and Mercer explained the results of that survey at a webinar earlier this month that OPA participated in. That webinar can be viewed here.
NOTE: These rules will be basis for pharmacy reimbursement moving forward. ODM plans to have the new fee schedule up and running for pharmacies by April 1, 2017, which is partly why they are moving so quickly on this. It is important that OPA and the Ohio Department of Medicaid get your feedback ASAP.
Please consider financial support of our legislative efforts by contributing to the OPA Pharmacy PAC. 100% of Pharmacy PAC money contributed by pharmacists goes to help candidates who support pharmacy in Ohio. Or if you'd like to make a corporate contribution to support OPA's investment in our advocacy program, please consider being a part of the OPA Legislative Defense Fund (LDF).