Primary Policy Issues

Dispensing Controlled Substances

LTC and hospice providers are experiencing significant delays in obtaining controlled substances prescriptions for their residents due to enforcement actions by the DEA against LTC pharmacies, pursuant to the Controlled Substances Act and its regulations. These actions, designed to reduce theft and diversion of Schedule II-V controlled substances, are instead resulting in residents left for hours, and even days, without adequate relief to treat pain, seizures, psychiatric and end of life symptoms.
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Independence of Consultant Pharmacists

CMS proposes to require that consultant pharmacist services for LTC facilities be independent of any affiliation with LTC pharmacies, pharmaceutical manufacturers or distributors as a consideration of the Conditions of Participation for LTC facilities in the Medicare program. If implemented, consultant pharmacists could no longer be employed by LTC pharmacies, and instead would need to be employed by or contract with the LTC facilities.
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Disposal of Controlled Substances by Long Term Care Facilities

The DEA is currently developing regulations for the surrender of unused controlled substances by LTC facilities on behalf of their residents, pursuant to new authority granted by the Secure and Responsible Drug Disposal Act of 2010. As LTC facilities are not eligible to be registered with the DEA, they are not allowed to send controlled substances off-site for disposal and therefore are not able to take advantage of off-site disposal methods designed to minimize environmental contamination.
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Short Cycle Dispensing

Section 3310 of the Patient Protection and Affordable Care Act requires Medicare Part D Plans to employ utilization management techniques to reduce the per-fill quantity of prescription medications dispensed to beneficiaries residing in LTC facilities. The intent of this "short cycle dispensing" provision is to reduce unused medications by moving from traditional 30-day fills to biweekly, weekly, or daily fills.
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