Summary of CMS Final Rule on Short-Cycle Dispensing
What is the timeline for implementation?
Beginning January 1, 2013, all pharmacies which are servicing long-term care (LTC) facilities, including mail order and retail pharmacies, will be required to adhere to this new regulation.
What is the maximum amount of days which brand drugs can be dispensed?
Brand drugs must be dispensed at 14-days-or-less.
Can generics be dispensed in a different quantity?
Yes, however CMS is encouraging shorter cycle based upon needs to the LTC facility. Having different quantities dispensed of brand and generic can be a cause for confusion and frustration with nursing staff.
Does this apply to liquids dispensed from the pharmacy?
No, this is applying only to the solid oral medications.
Is there costs savings to the nursing home which could be realized from shorter cycle dispensing?
Absolutely, the savings can vary dramatically depending upon how medications are packaged and dispensed by the pharmacy to the amount of waste that is generated by the Part A residents. Our internal studies have shown savings of nearly 4 hours per day in medication pass times and savings in excess of 10% of the total drug costs.
Does this rule apply to residents with Part D Plans?
Yes, it applies to all Part D sponsors as long as dispensing method technique is uniform within the facility. Further, Part D sponsors should NOT request credits for drugs that are dispensed but not consumed by the patient.
Are all unused medications required to be reported?
Yes, CMS is requiring that all unused drugs be reported by the plan sponsor.
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