As you know, the Long Term Care Pharmacy Alliance and other groups involved in providing medications to the nation’s nursing home residents have been urging the Centers for Medicare & Medicaid Services (CMS) to change its current policy which prohibits long term care providers including nursing homes, pharmacies and physicians from recommending a Part D plan to the nursing home residents they care for.

This is an important issue in the nursing home setting because most nursing home residents lack the practical ability analyze and choose a plan on their own.  As a result, most nursing home residents, being dual eligibles, have been randomly assigned a Part D drug plan by CMS without regard to whether the plan covers that resident’s prescribed drugs.   This has resulted in large numbers of nursing home residents being mismatched to plans that don’t meet their needs.

We hoped CMS would take the opportunity to change this policy when it released its Medicare Part D Marketing Guidelines for 2007.   Unfortunately, CMS failed to do so and the policy remains unchanged.   Of course, as this prohibition exists in sub-regulatory guidance, CMS can change this policy at any time and we continue to hope they will do so soon.

I wanted to keep you up to date on this issue.   LTCPA will continue to be in touch with you on this issue as we work for a better Medicare Part D program for the nation’s nursing home residents.