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Transcription:

Matt: Hello and welcome to Avalere’s eighth episode in a series of podcasts focused on the COVID-19. My name is Matt Kazan, and I am a Principal in the Policy Practice here at Avalere. I am joined today by my colleagues, Daniel Nam, who is an Associate Principal in the Policy practice, a pharmacist and attorney and Nick Diamond, a Consultant in the Policy Practice, who is also an attorney and public health expert. In today’s episode we will focus on what COVID-19 means for the state of the pharmacy business. Daniel, as the COVID-19 pandemic continues, what has been the impact on retail pharmacies?

Daniel: Sure, Matt. I am happy to answer that. As we are learning more of the unprecedented impact COVID-19 has had in the United States, Avalere has also been thinking through the impact for retail pharmacies and pharmacists. With social distancing, and the need to protect vulnerable patients, retail pharmacies may need to lean on alternative ways to get their medicines to their patients – in other words, increase delivery and mailing medications. But there are several questions pharmacies need to consider before this can happen.

• What role does traditional pen and paper type requirements play in today’s environment? I am thinking of about things like proof of consultation or signatures.
• What impacts would an increase in mailing of medications have on contracts with payers and state licensing requirements? For example, mailing medications to another state could trigger mail order licensing considerations in both states.
• How can pharmacists continue to help as a public health resource, and from a medical burden perspective? I do not think the need for pharmacists to play additional roles has ever been so obvious, especially with how pharmacists deliver vaccinations and testing.

Matt: Thank you, Daniel. Now Nick, Daniel has talked of the growing need of pharmacists’ skills but much of that is governed at the state level. Can you talk about how states’ scope of practice laws impact what pharmacists can and can not do? And how this may be impacting the response to COVID-19?

Nick: Yeah, absolutely Matt. This is something that is critical as we think of the scope of the role that pharmacists could play in the public health response efforts. As you alluded to, states have scope of practice laws, which in the case of pharmacists, are determined by a board of pharmacy in a state. These laws set out the types of testing pharmacists are able to perform, including types of immunizations and any limitation considerations. As we look ahead to the pharmacists’ role in the overall public health response to COVID-19, states’ scope of practice laws would have to align with the need to test for COVID-19 and administering a future COVID-19 vaccine.

Matt: Daniel, thinking of about what Nick just said, what is the intersection between the states’ scope of practice laws and federal reimbursement programs like Medicare?

Daniel: Sure. I would think of state and federal policies as the two necessary keys that pharmacists must have to open the door to providing services beyond dispensing and consulting. For our context here, we will be focusing on the Medicare Program, particularly the Medicare Part B program. As Nick said, states draw the boundaries of what pharmacists can and can not do within their professional licenses, and this can differ from state to state. On the other hand, the federal government usually decides which services are to be paid under Medicare, to whom, and at what level including any restrictions to such payments. So, for pharmacists to provide certain services under Medicare:

• the state would need to allow the service to be conducted by the pharmacists within their jurisdiction; and
• the federal government would need to reimburse pharmacists for those allowed services.

In doing so, you allow pharmacists to conduct services. Recently, we have been unpacking U.S. Department of Health and Human Services (HHS) guidance, which allows pharmacists to test for COVID-19. However, this is typically something states would do – and have done at varying lengths across the country. Given everything discussed, we are quite curious of the implications that these guidelines will have on state laws.

Matt: Thank you, Daniel. Now looking forward, we know that Congress, in COVID-19 legislation, has moved the coverage of a future COVID-19 vaccine to Medicare Part B. Nick, what is the current state of pharmacies administering vaccines covered today under Medicare Part B?

Nick: Yes, Matt, this has been an important issue for several years now, for a variety of stakeholders. Currently, under the Part B statute, pharmacists are not recognized as providers, which limits the types of services they can provide and bill for under Part B. Only certain immunizations, in a general manner, are covered under Part B – those include flu and pneumococcal. HHS created a pathway back in the 1990s, that allows pharmacists – whether in a retail setting or in the office setting – to apply to be a mass immunizer. This allows pharmacists to roster bill for the flu or pneumococcal vaccines in either of the two settings mentioned. It is important to note that guidance does not yet incorporate a future COVID-19 vaccine. Even though, per the recent legislation that you mentioned, a future COVID-19 vaccine would be covered under Medicare Part B. Current parameters of the guidance do not allow pharmacists to roster bill for that vaccine, which will be very challenging for pharmacists serving Medicare patients.

Matt: Thank you, Nick, that is helpful context and background. Daniel, thinking about that future state where a COVID-19 vaccine is available and covered under Part B, what specific challenges does that impose for pharmacies and pharmacists? And, can you also talk about the opportunities it may create?

Daniel: Sure, Matt. Like Nick stated, though Congress has allowed future COVID-19 vaccines under Medicare Part B, there does not seem to be a clear pathway for pharmacists to be reimbursed for COVID-19 vaccinations and perhaps testing. Despite the HHS guidance, scope and reimbursement for COVID testing is an open question for pharmacists. All of this should leave pharmacists asking:

• Are all COVID-19-related services currently allowed in my state? If not, is there a pathway to encourage the state to expand it to allow pharmacists to test for COVID-19?
• What is within the realm of possibility for getting reimbursed for services like COVID-19 vaccinations and testing? And, what does this pathway look like? Does one exist within guidance and regulation? Or, does it require legislative action?

It will come down to if we will get good answers to these questions, and where we are going to need to rely on both state and federal expertise, deep analytical skills, and access to Medicare claims data – all of which Avalere has.

Matt: Thank you, Daniel. Those are all important questions to think about. That wraps up today. Thank you, Nick and Daniel, for your insights. Thank you all for tuning in today, if you would like more information feel free visit to our COVID-19 intel center on our website. Thank you very much and have a great day!