On January 12, URAC submitted comments in response to the Centers for Medicare and Medicaid Services’ (CMS) proposed rule for Medicare Advantage. As part of the proposed rule, CMS requests feedback regarding the role that accreditation, namely accreditation of specialty pharmacies, plays in Part D. CMS noted anecdotal concerns that have been reported regarding the potential limiting nature of Part D contracts that require pharmacies to maintain Specialty Pharmacy Accreditation.

These anecdotal concerns are not surprising given the evolving nature of pharmacy quality management and our engagement with CMS. As we have done over the past several years, our comments remind CMS of the significant impact poor quality can have on patients who rely on increasingly complex medications.

Our comments to CMS strongly rejected suggestions that the value of accreditation as a quality assurance tool is dependent on the nature of Part D contracts. Regardless of how Part D sponsors build their networks, the value of accreditation does not change in that it is always a validator of quality uniquely focused on the skills and services required to appropriately care for patients.

CMS indicated in the proposed rule that it had received complaints from pharmacies that Part D sponsors have begun to require accreditation by multiple accrediting organizations. URAC indicated that we believe accreditation is an important independent validator of an organization’s quality. However, URAC does not support redundant requirements that increase the administrative burden pharmacies face. We believe, where there is substantial similarity among accreditors, one accreditation is sufficient to demonstrate an organization’s quality. Therefore, we view any requirement for URAC Specialty Pharmacy Accreditation coupled with an additional accreditation from another entity to be an unnecessary and redundant burden on pharmacies.

If you’re wondering if the above position invites URAC to be compared with other accreditors - the answer is yes. We know that our products have no true comparison with respect to the rigor of our standards and our process. It is with this in mind that we welcome comparisons and declare that there is no value added in a second accreditation requirement given the breadth and depth of our accreditation.

From a broader perspective, our comments called on CMS to take an active role in the pharmacy quality debate as we fear Medicare is at risk of falling behind nationally accepted principles of pharmacy management. While we acknowledge CMS’s decision not to define a “specialty pharmacy” for fear of an undue influence on the market, we note that there are broadly accepted, established principles of quality upon which CMS can engage to ensure Medicare enrollees are afforded the same level of quality care as commercially insured patients.

As federal and state policymakers continue to consider policies to address access to medications and pharmacies, I will keep you informed about URAC’s engagement and the impact of any adopted policies.

Please feel free to reach out if you have any questions!

Read URAC’s comment letter to CMS here.