Late last week, the Centers for Medicare and Medicaid Services (CMS) made two surprising announcements. First, a press release was sent out that CMS would not be enforcing provider restrictions for the administration of the anticipated COVID-19 vaccine in skilled nursing facilities (SNF), specifically referencing pharmacists. Following this press release, a second announcement shared the collaboration of CVS and Walgreens in the administration of the COVID-19 vaccine in long-term care facilities (LTCF). This week, we break down these announcements, what they mean, and the potential implications they may have.
Summary of the announcements and what they mean
The first announcement is relatively brief in length. The main purpose of this announcement is to share that CMS recognizes pharmacists as key providers of vaccinations and that patients living in LTCF are particularly vulnerable to COVID-19. Surprisingly, CMS highlights a key talking point of pharmacist provider status efforts for the past decade, that reimbursement for services is necessary to expand access to certain care. With this realization, CMS states that they will “exercise enforcement discretion” in order to “facilitate the efficient administration of COVID-19 vaccines to SNF residents”. With pharmacists already granted the authority to administer all CDC recommended vaccines to people above the age of 3 during the public health emergency, this opens the door for pharmacists to be reimbursed by CMS for the administration of the COVID-19 vaccine for LTCF patients once it is approved. The press release states that “CMS will allow Medicare-enrolled immunizers, including but not limited to pharmacies working with the United States, to bill directly and receive direct reimbursement from the Medicare program for vaccinating Medicare SNF residents.”
It is curious that pharmacies working with the U.S. are specifically called out rather than highlighting the individual practitioner, such as the pharmacist. This specification makes more sense as one reviews the next announcement of CVS and Walgreens collaborating to administer the COVID-19 vaccine to patients at LTCFs. In this second press release, The Pharmacy Partnership for Long-Term Care Program is introduced as a part of Operation Warp Speed (OWS). As a reminder, OWS is the current administration’s plan to operationalize the efficient distribution of the COVID-19 vaccine.
A key point of this announcement is that there will be no out-of-pocket costs to receive a COVID-19 vaccine by a pharmacist at a LTCF. This ties back to CMS’ first announcement that they will be exercising enforcement discretion of provider restrictions at LTCF to allow pharmacists to be reimbursed by CMS. Involvement in this program is not a requirement of LTCFs. Starting on October 19th, LTCFs can opt-in to participate once the COVID-19 vaccine is available. Additionally, it does not appear that pharmacist involvement is limited to those employed by CVS and Walgreens as it is stated in the second press release that LTCFs “can request to use their current pharmacy contracts to support COVID-19 vaccination.”
These announcements are a big deal for primarily two reasons. It is no surprise that pharmacists are being discussed as key providers of care at this time in the pandemic. Pharmacists have continued to come up in important discussions to provide vital healthcare services throughout 2020 due to their expertise and high accessibility by the public. These announcements are a big deal because it continues to highlight the importance of pharmacist provided care, especially in the response of public health emergencies.
However, with the focus of only two employers of pharmacists (CVS and Walgreens) to provide COVID-19 vaccines in LTCFs, one could question how this contained involvement could limit patient access to this vital vaccine. One of the primary questions that can arise when reflecting on the implementation of this policy is why CVS and Walgreens are only discussed. We could speculate that CVS and Walgreens locations may not be readily accessible to all LTCFs in the U.S., but we would rather let the data talk for itself. We pulled public domain data of LTCFs available from CMS and data on current pharmacy locations available from Homeland Infrastructure Foundation-Level Data (HFILD) to create a series of maps to show where LTCFs are located in the U.S. and where CVS and Walgreens pharmacies are located.
Above shows locations of LTCFs in the U.S according to CMS.
Above shows locations of CVS (green) and Walgreens (pink) pharmacies in the U.S according to HFILD.
One can observe there is a stark difference in the location of LTCFs as compared to where CVS and Walgreens pharmacies are located. Unsurprisingly, we observe that CVS and Walgreens are primarily located in urban areas, which could leave LTCFs in rural areas with limited access to pharmacist provided COVID-19 vaccines. To exemplify this difference let’s take a look at a specific state example, Colorado:
Above shows the location of LTCFs in Colorado according to CMS.
Above shows the location of CVS (green) and Walgreens (pink) pharmacies in Colorado according to HFILD.
Above shows the locations of all pharmacies in Colorado according to HFILD.
One can see that CVS and Walgreens pharmacies are located primarily in urban areas, whereas other pharmacies are more accessible in the rural communities, where additional LTCFs are located. With the focus of this partnership between pharmacists and LTCFs, it would make more sense to open this opportunity up to all pharmacists rather than limiting it to those employed by CVS and Walgreens in order to ensure all LTCF patients receive this vital vaccine. It is unclear the requirements for pharmacists outside those employed by CVS or Walgreens to partner with a LTCF to provide the COVID-19 vaccine. As details are released regarding this program, if barriers are presented to these pharmacists, consider contacting the U.S. Department of Health & Human Services, CMS, and your elected leaders. As can be observed from these geographical locations, we need all pharmacists on board ready to provide this care, not just a select few. If you are interested in learning more about where LTCFs are located in relation to CVS and Walgreens pharmacies, check out our interactive maps at the end of this article.
The second reason that these announcements are important is because CMS has highlighted both the importance of reimbursement for services and pharmacists in a statement together. One could take this as proof that advocacy is working. For years, pharmacists, students, and other advocates for the profession of pharmacy have shared with elected leaders the challenges surrounding the current reimbursement model in pharmacy. The original tying of reimbursement to a product has resulted in challenges as the roles and responsibilities of the profession have evolved to be more focused on the provision of patient care services. As the sustainability of a dispensing foundation business model has begun to shake in current years, members of the profession have advocated even harder for the shift of the pharmacist business model to be more tied to the services being provided rather than the products.
Although it is a small step to only be reimbursed for the provision of a COVID-19 vaccine in a LTCF during the public health emergency, it is a step, nonetheless. We have discussed throughout this blog, the power of incremental change rather than the expectation that one bill should accomplish everything. What we as a profession must do at this moment is not turn our backs on this opportunity. This is the chance for the pharmacist to show the therapeutic and economic value associated with the care we provide. Elected leaders will be watching and how the profession responds could have a direct impact on future legislative efforts.