In response to a proposed regulation that would mandate separation of consultant pharmacy services from other pharmaceutical providers in long-term care, the American Society of Consultant Pharmacists (ASCP) today expressed concern to the Centers for Medicare & Medicaid Services that the method and timeframe suggested for implementing the proposed rule is impractical and cannot be effectively carried out as written without sacrificing quality of care.
The proposed rule, published October 11 in the Federal Register, requires that consultant pharmacy services for LTC facilities be independent from any affiliation with LTC pharmacies, pharmaceutical manufacturers or distributors, beginning January 1, 2013. If implemented, consultant pharmacists could no longer be employed by LTC pharmacies that provide medications to residents under contract with LTC facilities. Consultant pharmacists instead would need to be employed by LTC facilities or contract directly or indirectly with the facilities.
Official ASCP policy supports the independence of consultant pharmacists from LTC pharmacies that provide medications to residents of a facility. In the absence of separation, the society suggests best practices for consultant pharmacists and LTC pharmacies to avoid any potential conflicts of interest. Examples of such best practices include requiring separate service agreement contracts with LTC facilities, providing consultant pharmacist services at fair market value and ensuring that consultant pharmacists are empowered to make independent judgments about the appropriateness of medication use for each patient.
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