Long-Term Care Facilities (LTC)
Residents of long-term-care (LTC) medical or nursing facilities with psychiatric illnesses are a unique and vulnerable population with special pharmacy needs. All facilities that comply with Medicare and Medicaid conditions of participation are covered under the new Part D prescription drug benefit. These are primarily nursing home facilities.
Other living arrangements such as assisted living facilities, other facilities recognized by state law, group homes for the developmentally disabled, and other forms of congregate living arrangements regulated by the states, but not by the Federal government, are not covered as LTC facilities under Part D, and patients who reside in these facilities will be auto-enrolled (if dual eligible) or will have to individually enroll in a Part D plan and access their prescription drugs through regular pharmacies that have contracted with the PDP or Medicare Advantage plan that they are enrolled in. In either case, they will access their prescription drugs through the pharmacies that have contracted with their PDP or Medicare Advantange plan.
Questions Answered
Yes. CMS stated that PDPs may need to provide a temporary “first fill” supply order for a limited quantity of medication prescribed by the attending physician until an appropriate liaison between the facility, the attending physician, and the plan’s LTC pharmacy on behalf of the resident can be achieved. A transition period of 90 to 180 days is specified as being appropriate for residents of nursing facilities on multiple medications who require some changes to their medication regimen in order to accommodate plan formularies. See section on Transition & Continuity of Care.
How will individuals in LTC facilities with both Medicare and Medicaid (dual eligibles) be affected?
Many dual eligibles reside in LTC facilities and receive their prescription drugs through a LTC pharmacy. As of January 1, 2006, all patients with both Medicare and Medicaid in LTC facilities will automatically transition to the new Medicare prescription drug benefit and will no longer receive their prescription drugs through Medicaid. LTC pharmacies will contract directly with Medicare prescription drug plans (PDPs) and will not bill Medicaid.
How will LTC residents select a plan?
LTC residents who have both Medicare and Medicaid (dual eligibles) will be randomly auto-enrolled into a drug plan unless they make an alternative selection based on individual existing treatment needs. Those residents with only Medicare will have to enroll into a PDP just like other Medicare beneficiaries (see section on Enrollment & Eligibility).
Will my patients in LTC facilities be subject to co-pays?
Dual eligibles residing in LTC facilities will receive continuous prescription drug coverage with no premiums, no deductibles, and no co-pays. Other residents, with only Medicare, may be subject to the standard costs of the Medicare prescription drug program, including co-pays, if they are not eligible for Extra Help, the low-income subsidy being offered by CMS. (See sections on Patient Costs and Low-Income Subsidies).
How will formulary restrictions affect LTC patients?
Prescription drug plans are expected to accommodate the needs of LTC residents within a single formulary structure by providing coverage for all medically necessary drugs at all levels of care. However, utilization management tools may be used to regulate access to specific drugs. There are exceptions processes to override restrictions (See section on Coverage Determinations, Exceptions, and Appeals.)
What if my LTC patient’s drug is not on the PDP formulary?
CMS has stated that if a patient is stabilized on certain drugs, the new plan must continue to provide these same drugs when the patient requires a refill, so this may help solve the problem of plan selection for them. However, the plan is not obligated to provide the drug in the same form or dosage the patient has been getting. Therefore, if the patient’s medication is not available as needed, an exception will have to be filed with the PDP or the patient will have to look for a PDP that can supply the necessary drugs.
Which LTC pharmacies will participate in the program ?
CMS expects that each LTC facility will select at least one eligible Network LTC Pharmacy (NLTCP) to provide Medicare drug benefits to its residents.
Part D plans will be required to offer a contract to any pharmacy willing to participate in its LTC pharmacy network so long as the pharmacy is capable of meeting certain minimum performance and service criteria (and relevant state laws governing the practice of pharmacy in the LTC setting) and any other standard terms and conditions established by the PDP for its network pharmacies.
Patients should be able to check www.medicare.gov in fall 2005 to compare the available prescription drug plans in their area and their participating pharmacies.Current as of 9-26-2005
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