Managing a Clinical Practice

Mary Ann Kliethermes, Pharm.D.

Midwestern University
Downers Grove, Illinois
 Managing a Clinical Practice

Managing a Clinical Practice

Mary Ann Kliethermes, Pharm.D.
Midwestern University
Downers Grove, Illinois

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-169
 Managing a Clinical Practice

Learning Objectives 2. Documenting patient care services efficiently is an

important aspect to manage in your clinic. Docu-
1. List three critical functions to complete on an an- mentation of patient care encompasses many goals,
nual basis to sustain a practice. including meeting legal requirements and commu-
2. Describe various methods of communication and nicating with other health professionals. In today’s
evaluate the pros and cons as they apply to your health care climate, which is potentially the most
setting. important requirement of a documentation system?
3. Develop a documentation template according to the A. Easily retrievable data for tracking outcomes.
recommended elements for documenting a pharma- B. A portal where the patient can view his or her
cist direct patient care visit in an ambulatory setting. personal information.
4. Develop a robust quality assessment program for C. Payer audits of health information.
your clinical service using the balanced scorecard. D. Use of SNOMED CT (Systematized
5. List the three domains for quality measurement in Nomenclature of Medicine—Clinical
health care. Terminology) codes for transmission of
6. List three methods used to improve quality in an clinical information.
organization.
7. Analyze sources of quality measures, and select 3. The Patient-Centered Primary Care Collaborative
measures important to your practice site or patient (PCPCC) has established recommendations for
population. documenting a comprehensive medication man-
8. Describe the limitations and challenges of quality agement visit with a patient. You are developing
measurement. a template according to the recommendations. As
9. Develop a credentialing and privileging process to you develop the section about communicating your
ensure the competency of pharmacists providing recommendations, which is considered the optimal
direct patient care in the ambulatory setting. framework for documenting a drug problem?
10. Differentiate pharmacist billing opportunities be-
A. Address indication, efficacy, safety,
tween a hospital-based clinic, physician office, and
and adherence.
community pharmacy.
B. Use the situation/background/assessment/
11. List the requirements for “incident-to” billing.
recommendation (SBAR) or the situation/
12. Develop a proposal for pharmacists to participate
task/intent/concern/calibrate (STICC)
in wellness visits and transition-of-care services for
communication technique.
Medicare beneficiaries.
C. Address efficacy, adverse reactions, costs,
13. List the MTM (medication therapy management)
and patient satisfaction.
codes and describe how they may be used to bill for
D. Address unneeded or needed therapy, the drug
a patient visit.
dose, adverse drug reactions, and adherence.
Self-Assessment Questions
Answers and explanations to these questions can be
found at the end of the chapter.

1. A key to maintaining your practice is keeping your

policies and procedures, as well as your collabora-
tive practice agreements, current. Which option
best reflects how often these documents are recom-
mended to be reviewed and updated?
A. Every 6 months.
B. Every year.
C. Every 3 years.
D. Every 5 years.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-170
 Managing a Clinical Practice

4. To improve the quality of health care in the United 7. You plan to request an additional pharmacist for
States, the government has set a goal of the Triple your clinic and plan to support that addition with
Aim, which is better care for individuals, reduction the payment structure in the HOPPS regulations
in per capita costs, and better population health. from the Centers for Medicare & Medicaid Ser-
Knowing that these goals are driving Medicare pay- vices (CMS). Which best describes the setting your
ment policies for your strategic plan, which is the op- clinic must be in to use this regulation?
timal measure that would best address your services A. A community pharmacy.
as a clinical pharmacist and your contribution to the B. A hospital-owned clinic.
health of the patient population of your organization? C. A physician office.
A. Number of patients receiving medications D. A federally qualified health center (FQHC).
without a documented medical indication.
B. Number of patients who report an improved 8. Your practice, which focuses on diabetes, is in a
understanding of when to take their clinic building where there are primary care, sev-
medications after using your service for eral specialty offices, and a pharmacy. Your office
6 months. is in the internal medicine suite. You plan to use
C. Number of patients who report they can now incident-to billing. Which option provides the best
afford their medications with at least one example of the provider that may serve as your su-
pharmacy services visit. pervising provider?
D. Incidence of adverse drug events leading to A. The endocrinologist in the floor above yours.
hospitalizations in patients older than 65 years B. The hospitalist across the street in the hospital.
seen by pharmacists in your clinic. C. The family practitioner in the suite across
the hall.
5. You are developing a proposal to your administra- D. The nurse practitioner in your internal
tors outlining how your services will assist the or- medicine suite.
ganization in the new payer contracts secured for
Medicare Part C patients. The service the pharmacy 9. Which is the most accurate statement regarding
team provides is medication therapy management MTM codes?
(MTM), and currently, all patients taking eight or
A. Payment is adjusted by varying costs across
more medications for chronic conditions are auto-
the country, or relative value units (RVUs).
matically referred for evaluation to the pharmacy
B. MTM codes are required for billing MTM
clinic. Which would be the optimal measure set to
services under Medicare Part D.
focus on in your efforts to improve both patient and
C. MTM codes are based on medical complexity.
financial outcomes?
D. MTM codes are based on time spent during
A. “Meaningful-use” measures. a visit and if the encounter is an initial or
B. Healthcare Effectiveness Data and repeated visit.
Information Set (HEDIS) measures.
C. Physician Quality Reporting System
(PQRS) measures.
D. Five-star measures.

6. Which is the best example of the method that grants

health providers, such as clinical pharmacists,
approval to perform a set of services within their
scope of practice in a clinic?
A. Privileging.
B. Credentialing.
C. Collaborative practice.
D. Licensure and training.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-171
 Managing a Clinical Practice

Summary of Case Examples

1. You have completed 1 year of services in the health-system outpatient clinic with primary care and medical
specialty services. The initial purpose of your clinic was to assist in the management of patients with
heart failure and chronic obstructive pulmonary disease (COPD) after hospital discharge with the goal of
reducing 30-day readmissions. You currently are analyzing the results of the impact of your service on 30-
day readmissions. Your services have been well received within your organization, and you currently enjoy
a well-established practice. Your practice has grown significantly, including other patient referral types,
particularly patients with diabetes in need of better disease control and education. Recently, however, it has
become increasingly difficult to schedule patients with COPD and heart failure within the 72 hours post-
discharge goal because of your patient volume.

2. The community pharmacy chain for which you manage clinical services is now 6 months into a contract
with the local accountable care organization (ACO). Stipulated in the contract is a formal review of services
provided at 6 months. The 6-month review will primarily address processes. Another report focusing on
quality measures and patient outcomes is due at 12 months. A lack of optimal communication processes has
emerged as an important barrier to efficiency in services.

3. You are a co-funded ambulatory practice assistant professor with a practice site at a family practice office.
The providers in the office have spent the past year retooling the practice to a patient-centered medical home
(PCMH) model of care. You have been providing clinical services to this office for 1 year. You have had
students and residents at the site. The practice is pleased with the clinical pharmacy services and now wants
to explore billing opportunities. The practice is beginning to appreciate how best to use your services and
would like to discuss expanding the scope of what you provide to the practice.

Managing a Clinical Practice

With an established practice, the focus will shift to maintaining and growing a successful clinical service. Similar to
starting such a service, there are key activities that you will need to pay attention to simultaneously.

I. GENERAL ONGOING MANAGEMENT

Domain 4, Task 4,
A. Maintaining Policy and Procedures. Despite careful planning and good intentions, some processes
will not work as well as envisioned. Policies and procedures are guides that provide a level of
standardization and quality. If issues are identified in the early stages of implementation, address
and revise them as soon as possible.
1. Review policy and procedures yearly. Doing so will keep the review process manageable. Waiting
too long will result in outdated policies that may require a major overhaul, often resulting in a large
workload for you and your staff.
2. Assign the reviewing responsibility to the staff members who perform the functions in the policies.
Because they perform the process daily, they will be able to detect discrepancies that may need to
be addressed.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-172
 Managing a Clinical Practice

B. Maintain Your Practice to Meet the Minimum Current Standards of a Pharmacist Ambulatory Care Practice.
Current minimum standards of patient care in ambulatory care are described in the following references: Am
J Health Syst Pharm 1999;56:1744-53; Council on Credentialing in Pharmacy 2009; U.S. Public Health Service
2013; American Pharmacists Association and National Association of Chain Drug Stores Foundation 2008;
Patient-Centered Primary Care Collaborative 2012; and Joint Commission of Pharmacy Practitioners 2014.
1. Gathering patient information from the medical record and interviewing patients or caregivers
to obtain pertinent information needed for patient care
2. Assessing the legal and clinical appropriateness of the medication regimen
3. Identifying, resolving, and preventing medication-related problems
4. Participating in medication and disease-state therapy decision-making and development of a
patient plan of care
5. Educating patients and caregivers on disease, medication therapy, adherence, and preventive health
6. Monitoring the effect of medication therapy on patient health outcomes
7. Documenting services provided and creating and maintaining medication profiles, medication-related
plans of care, and other needed patient care documentation

C. Stay Up to Date. Health care and practice is dynamic and constantly changing. Find effective processes for
staying abreast of current practice. Pay particular attention to the following areas:
1. Pharmacy practice and therapeutic literature
a. Pharmacy and other appropriate practice organizations
i. Regularly review respective journals, reports, and web-based resources.
ii. Become involved with at least one organization in some manner.
b. Therapeutic literature
i. Medical journals pertinent to your practice (e.g., primary care, general internal medicine,
diabetes, cardiology)
ii. Guidelines. These are often published in the respective specialty medical journals. You can
also subscribe to the Agency for Healthcare Research and Quality’s (AHRQ’s) website (www.
guideline.gov), which will send weekly e-mails of new guidelines available in the database.
2. Laws and regulations
a. State board of pharmacy. Review state laws and the rules and regulations for pharmacy practice
b. State government. Laws that may change, affecting practice and state-sponsored health insurance
plans (e.g., Medicaid, third-party payers)
c. Federal governmenth
i. U.S. Food and Drug Administration. Approves new medications and issues warnings or other
recommendations for already-approved medications
ii. U.S. Department of Health and Human Services and the Centers for Medicare & Medicaid
Services (CMS). Determines the rules and regulations for federally sponsored health care
or Medicare
iii. Centers for Disease Control and Prevention. Determines the rules and standard procedures for
point-of-care testing, immunizations, and management of patients with transmittable diseases
iv. Protection of patient information (Health Insurance Portability and Accountability Act
[HIPAA])
d. Other organizations
i. Occupational Safety and Health Administration (OSHA) guidelines
ii. Accreditation organizations. Establish standards for quality and safety. An accredited
practice is often required by payers for contractual relationships and/or payment.
iii. Joint Commission
iv. National Committee for Quality Assurance (NCQA) PCMH recognition
v. Center for Pharmacy Practice Accreditation (CPPA)

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-173
 Managing a Clinical Practice

D. Update and Review Your Collaborative Practice Agreement on a yearly basis or as dictated by state laws,
rules, and regulations.

Practice Case 1

You are pleased to be receiving referrals for patients with diabetes in your clinic because this area of practice
has always been a strong interest of yours. However, these referrals are slowing you down in the clinic because
you do not have a collaborative practice agreement established for diabetes management. In addition, patients
are calling your service instead of their medical providers for refills of medications, which was not included in
your original collaborative practice. Moreover, you would like to discuss the new cholesterol guidelines with
your team so that you are clear on their interpretation and approach, particularly for patients with heart failure.
For the yearly review of the program with the medical group physicians and administrators, you request that
these issues be placed on the agenda. During the meeting, it was agreed to add authorization of refills to the
collaborative practice agreement. An endocrinologist will be recruited to review your service, and you will work
with that physician to develop a diabetes management collaborative agreement. You will provide an in-service
on the new cholesterol guidelines to key physicians with the goal of developing an agreed-on standard patient
approach for the clinic.

This case demonstrates a real situation in showing how much can change in 1 year. Therefore, it is good
practice to set up a standard annual review of the documents that guide your daily practice.

II. DETERMINING HOW YOU WILL COMMUNICATE

Strong communication processes are one of the most important aspects of ambulatory care. The success of the
pharmacy service(s) will depend on how effectively you communicate, not only with patients but also with all the
health care providers involved in a patient’s care.

All patient encounters need to be communicated to other members of the health care team. Setting up standard
processes and structures to communicate will help make the program more efficient. Communication must occur
bidirectionally between all members of the health care team.

A. Health Care Communication

1. Methods of communication that you may choose to use
a. Face-to-face
i. Benefits
(a) Collegial and builds relationships
(b) Allows body language interpretation
(c) Immediate answer is usually provided.
(d) There exists an ability to elaborate and have in-depth discussions as needed.
ii. Barriersh
(a) May be inefficient and disrupt clinic or patient flow
(b) Works only if you are physically located near other providers
b. Telephone or page
i. Benefits
(a) May be able to receive immediate answer
(b) There exists an ability to elaborate and have in-depth discussions as needed.
(c) Collegial because still person-to-person contact

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-174
 Managing a Clinical Practice

ii. Barriers
(a) Getting hold of the person may be difficult.
(b) May be intrusive
(c) If unable to reach the person or need to use voicemail, this may negate the benefit
of person-to-person contact
c. Fax and voicemail
i. Benefits
(a) Record of communication
(b) Nonintrusive
ii. Barriers
(a) May need assistant to perform
(b) Confidentiality issues; fax may go to wrong place
(c) Loss of collegial aspect with personal interaction
(d) No elaboration or discussion possible
(e) Misinterpretation may occur because of the need for brevity.
(f) Requires additional effort to scan or document in the electronic medical record (EMR)
(g) Delay in response
d. Electronic messaging. Currently, primarily done by e-mail, but may include other forms of
messaging, such as texting and Twitter, as these venues continue to grow and expand
i. Benefits
(a) Record of communication
(b) May be nonintrusive
(c) Easy and convenient
(d) No intermediaries needed
ii. Barriers
(a) May not be secure or private method of communication
(b) Loss of collegial aspect with personal interaction
(c) No elaboration or discussion possible
(d) Misinterpretation may occur.
(e) Delay in response; however, may be less delayed than other methods because
of convenience
e. EMR
i. Benefits
(a) Accessible to all providers; aids efficiency
(b) Written record of communication
(c) No confidentiality issues
ii. Barriers
(a) Unable to discuss an issue
(b) Communication is permanent and therefore not amenable to an off-the-record type of
consultation.
(c) Without direct notification, other provider may not be read
(d) Loss of collegial aspect with personal interaction
f. Team huddles or meetings. Quick meetings (synonymous with a sports team huddle) in which the
team discusses patient cases and develops a plan of care. This simple communication method is
a cornerstone in the functioning of new models of care such as the medical home. Frequency of
team huddles depends on the needs of the team.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-175
 Managing a Clinical Practice

i. Benefits
(a) Collegial and builds relationships
(b) Allows body language interpretation
(c) Immediate answer
(d) Ability to elaborate and have in-depth discussion as needed
(e) Efficient
(f) No confidentiality issues
(g) Allows interdisciplinary perspective when addressing patient needs
(e.g., primary care physician, pharmacist, nutritionist, behaviorist)
ii. Barriers
(a) Optimal for team members to be in the same location
(b) Balance between time needed for huddles and a busy workload. Knowing how to
perform a huddle is key so that the value is apparent.
2. Tools for effective communication regarding patients
a. Patient plan of care – One plan shared by all
i. Everyone is working toward the same goals (including the patient).
ii. Responsibilities for action within the plan of care are clear.
b. Medication list – Should contain information other providers need and in an easy-to-use format
i. Basic patient demographics (e.g., name, date of birth, height, weight)
ii. Date prepared, preparer name, and contact information
iii. Allergies and intolerances with symptoms the patient experienced
iv. Medications listed under the conditions for which they are used
v. Medication generic name with trade name in parentheses, total dose taken, and direction
for taking it, together with how supplied, if needed, in parentheses
vi. Start dates, if known
vii. Include herbals, over-the-counter medications, and vaccinations.
viii. Prescribing providers, their specialty, and contact information
ix. A list of medications that were discontinued and reason for discontinuance
3. Continuity of care. After a patient visit, it is your responsibility to communicate the important aspects
of that visit to other providers or caregivers who need the patient information related to your visit.
This communication should include the following:
a. Updates or changes to the plan of care with the subsequent expectations and follow-up
b. Any new, pertinent patient information discovered
c. Adherence/persistence with medications
d. Drug-related problems
e. Education or advice provided

B. Internal Communication. Determine how to interact with team members caring for a mutual patient. Your
physical proximity to the other team members is critical in setting up the communication process. There
is no standard method for directly communicating within a patient’s health care team. Each situation may
dictate a preferred method, as may each provider.
1. Notify other providers of how you plan to communicate with them for routine and
acute medical situations.
2. Determine a standard method for obtaining needed information from others.
a. AHRQ. Improving Medication Safety in High-Risk Medicare Beneficiaries Toolkit (http://
effectivehealthcare.ahrq.gov/index.cfm/search-for-guides-reviews-and-reports/?productid=1186
&pageaction=displayproduct). Provides an easy-to-complete one-page form that can be sent to
other providers to gather key patient information you may need to provide your services

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-176
 Managing a Clinical Practice

b. As a standard function during their rotations, pharmacy rotation students could pull data from
an EMR or other sources.
c. EMR pharmacist documentation. Your EMR vendor can design a template in which key
information you may need will auto-populate the template from data already in the EMR.
3. Determine which providers may deviate from the standard method and prefer a different means of
communication (e.g., a fax vs. a page). Keep a record of the communication process for your primary
team members or other key providers.

C. External Communication. All external communications are considered transitions of care. Establish
standard methods to communicate patient information between providers, organizations, and settings
outside your service and organization.
1. Information that should be communicated to the next setting should be the same as noted already
under continuity of care.
a. Updates or changes to the plan of care with the subsequent expectations and follow-up
b. Any new, pertinent patient information discovered
c. Adherence to/persistence with medications
d. Drug-related problems
e. Education or advice provided
2. Hospital discharges. Quality standards have been established for this transition, a transition that is
known to have the risk of significant medication-related problems. This may be a tool you wish to use
or modify in your clinic.
a. Standards for discharge documentation based on National Quality Forum measure
i. Transition record: Patient’s diagnosis, treatment, and care plan provided to patient in printed
or electronic format and transmitted to the facility/physician/other health care professional
providing follow-up care
ii. Current medication list: All medications to be taken by patient after discharge, including all
continued and new medications
iii. Advance directives: A legal document that allows patients to express their wishes for medical
care at end of life, or when they may be unable to do so. The transition should contain a
statement of what the wishes are for the patient (e.g., do not resuscitate).
iv. Documented reason for not providing advanced care plan
v. Contact information/plan for follow-up care
vi. Plan for follow-up care: Includes postdischarge therapy needed, any durable medical
equipment needed, and family/psychosocial resources available for patient support
vii. Primary physician or other health care professional designated for follow-up care
b. Standard 24-hour/7-day contact
c. May be by telephone
d. In efforts to ensure coordination of care, you may find several individuals representing various
health care groups or providers calling a patient post-hospitalization. To avoid overburdening the
patient, be aware of others who plan to contact the patient and coordinate these efforts because
too many organizations calling a patient can be as negative as no coordination.
e. Office transition-of-care visit is a billable visit (addressed later in this chapter).
3. Long-term care
a. No standards
b. Often difficult to obtain information because there is no point person who can provide the
information or that person is not readily available
c. Patients often discharged with their medications in the blister packets used in the long-term
care setting, which may be confusing to patients

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-177
 Managing a Clinical Practice

4. Specialists and other providers: Home nursing. Home visiting nurses may be a very useful resource
because they can assess how patients are functioning in their home. These providers are required to
perform an extensive home assessment that includes a list of medications found in the home.
5. Others. In the new models of care, such as ACOs and medical homes, community based workers,
such as listed below, are part of the health care team.
a. Case workers
b. Community health workers
c. Rehabilitation centers

III. ESTABLISH A STANDARD PROCESS FOR DOCUMENTATION

Domain 4, task 1, item 2

A. Goals of Documentation. Several goals need to be achieved with documentation, as listed below.
It is important to keep these in mind when developing your documentation templates and processes.
1. Meet professional standards and legal requirements.
2. Communicate with other health professionals.
3. Establish accountability for medication-related aspects of direct patient care.
4. Facilitate transitions and continuity of care.
5. Create a record of critical thinking and judgment.
6. Provide evidence of provider value and workload.
7. Justify reimbursement for cognitive services.
8. Provide data for tracking patient health outcomes.

B. Electronic Portals for Documentation

1. American Recovery and Reinvestment Act of 2009 or the Health Information Technology Act
has changed the landscape for documentation, creating the meaningful-use initiatives. The act
incentivizes health care organizations to use electronic portals for documentation.
a. Health information exchanges – Congress allocated funding for each state to develop a process
for electronic health information exchange. For more information, visit the government website:
www.healthit.gov/providers-professionals/health-information-exchange/getting-started-hie.
b. Systematized Nomenclature of Medicine—Clinical Terminology (SNOMED CT) codes will
be the standard for health information exchange. Medication therapy management (MTM)
codes are currently under development for SNOMED by the Pharmacy e-health Information
Technology Collaborative.
2. Terminology for electronic portals for documentation
a. Electronic health record (EHR): Individual patient medical record digitalized from many
locations or sources, including patient access
b. EMR: Portal that shares relevant patient information among health professionals
c. Personal or patient medical record (PMR): A record of health information created for or by an
individual patient
3. Feasibility of using the EMR for pharmacists in the ambulatory setting
a. Often, structured primarily for the physician and may not meet the documentation needs
of a pharmacist. For example, ability to pull the data from various fields in the EMR into a
note template may not exist for the particular needs of a pharmacist (e.g., data from vendor
prescription refill hubs).
b. Potential access issues if working virtually or offsite

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-178
 Managing a Clinical Practice

c. The EMR (often built for physician workflow) may not accommodate the pharmacist work
process and may affect the efficiency of pharmacy workflow. For example, medication lists
located at the beginning of a template may not be updated when changes are made because they
are not visible to trigger the need to update the medication list or they require an action to return
to a different screen, causing a disruption in workflow.
d. Pharmacist documentation often too long and cumbersome
4. Solutions for documentation difficulties
a. Collaborate with Information Technology department (IT) to determine the flexibility of the
EMR to meet pharmacists’ needs.
b. Create a workflow process and templates for IT to incorporate into the EMR.
c. Interface pharmacist documentation software into the EMR.
i. Expensive
ii. Pharmacist documentation software is early in development.
d. CMS Medicare evaluation and management (E/M) documentation requirements. Documentation
must state that the service is medically reasonable and necessary and describe the work the
provider performed. Required for Medicare Part B billing (addressed later in this chapter). You
will note that the requirements are physician focused; however, when pharmacists are providing
and billing their services “incident-to” physicians, they must follow the E/M requirements.
i. Four levels of service with increasing complexity (and therefore reimbursement) from “a” to “d”
(a) Medical problem focused
(b) Expanded medical problem focused
(c) Detailed
(d) Comprehensive
ii. History component – Information provided should substantiate medical decision-making.
(a) Chief complaint
(b) History of present illness (HPI)
(c) Past, family and social history (PFSH)
(d) Review of systems (ROS)
iii. Examination: Physical examination according to body area or organ system
iv. Medical decision-making
(a) Assessment – Includes list of diagnoses or potential diagnosis
(b) Must address the chief complaint
(c) Plan – Must list orders
v. Four levels of complexity or risk with medical decision-making. This factors into payment
for the service.
(a) Minimal
(b) Low
(c) Moderate
(d) High
5. Documentation recommendations: The Patient-Centered Primary Care Collaborative (PCPCC)
Guidelines for the Practice and Documentation of Comprehensive Medication Management in the
Patient-Centered Medical Home. These recommendations have the input of experts from several
disciplines, including physicians, regarding the desired content of a pharmacist’s note.
a. Assessment of the patient’s medication-related needs
i. All medications reviewed and documented
ii. Patient medication experience is discussed and recorded.
iii. Medication history, including allergies/reactions
iv. Review and document current medications and doses; how they are actually being taken
v. Each medication assessed for indication or condition.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-179
 Managing a Clinical Practice

vi. Patient clinical status is assessed for each medication and condition for indication,
appropriateness, and effectiveness.
vii. Clinical goals of therapy for each medication
b. Identifying the patient’s medication-related problems by asking the following questions:
i. Appropriateness of the medications
ii. Appropriate for indication
iii. Is there an indication not being treated or prevented?
iv. Effectiveness of the medication
v. Is it the most effective product?
vi. Is the dose appropriate, and are the goals of therapy achievable?
vii. Safety of the medication
viii. Patient experiencing any adverse events?
ix. Is the dose too high?
x. Adherence: Is the patient able and willing to take medication?
c. Recommended documentation framework for drug problems
i. Indication
ii. Effectiveness
iii. Safety
iv. Adherence
d. Plan of care
i. Intervention to solve problems
ii. Goals of therapy
iii. Education for self-management
iv. Outcome variables to be monitored
v. Follow-up time interval
6. Center for Pharmacy Practice Accreditation (CPPA) Community Pharmacy Practice Standards
a. Standard 1.4.1: “Systems that allow documentation into a patient record of appropriate medical/
health information: Medication list, immunizations, allergies, laboratory values, diagnoses, and
other information required to deliver patient care services”
b. Standard 2.1.1.5: “Appropriate documentation and communication of patient care to physicians
and other health care providers”
c. Standard 2.1.2: “Pharmacists deliver MTM services: ….Whereby pharmacist documents the
MTM visit in the patients chart, including goals of therapy, care plan, interventions and referrals,
communication with other providers, in a retrievable format that is accessible to all pharmacy staff”
7. American College of Clinical Pharmacy documentation standards of practice: “Clinical pharmacists
document directly in the patient’s medical record the medication-related assessment and plan of care
to optimize patient outcomes. This documentation should be compliant with the accepted standards
for documentation (and billing, where applicable) with the health system, health care facility,
outpatient practice, or pharmacy in which one works.”
a. Use the format of a traditional SOAP note or other standard framework.
i. Medication history
(a) Summary of medication-related health problems (i.e. symptoms, achieving goals of therapy)
(b) Patients’ current and past medication use
ii. List of all current medications
(a) Attitudes
(b) Adherence
b. Allergies and adverse drug event history

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-180
 Managing a Clinical Practice

c. Active problem list

i. Current health conditions and status of each condition, emphasizing medications and
medication-related problems
ii. Any additional medication-related problems or other medication issues unrelated to current
health conditions
d. Plan of care
i. Medication therapy plan (drug, dose, route, frequency, and relevant monitoring parameters)
ii. Plans for implementation
e. Plan for follow-up, evaluation, and future visits

Practice Case 2

In establishing your relationship with the ACO, you decided to use current pharmacy medical office
communication processes because that was determined to be least disruptive to pharmacy operations. The
MTM referrals were sent through a computerized physician order entry process to the pharmacies for the MTM
services. The pharmacist completing the MTM services would then send a fax back to the physician office with
recommendations. Access to the ACO EMR was not provided in the original agreement because of HIPAA
(Health Insurance Portability and Accountability Act) concerns. The agreed-on decision was to use the patient
information tool from the AHRQ MTM toolbox. The MTM pharmacist would contact the office and ask the
medical assistant to fill out that tool and return it to the pharmacy after a referral had been established. Process
analysis identified the following concerns. The AHRQ patient information tool was not being completed in a
timely manner for the visit because of medical assistant workload. The pharmacists providing MTM noted that
it was difficult to contact physicians because each preferred his or her own method of communication (e.g., page,
faxed note, telephone call). In addition, it was difficult to keep track of the desired communication strategy
because of the many providers. The physicians stated that the SOAP notes from the pharmacists were too long
and that it was difficult to quickly identify the pharmacists’ recommendations. Moreover, different pharmacists
used different note styles. You meet with the medical director to discuss the communication barriers. Together,
you develop a proposal to administration that discusses the pros and cons of EMR access by pharmacy. Using
the plan, do, study, act cycle (PDSA) quality improvement process, members of the pharmacy team develop
a standard template for MTM using the PCPCC documentation recommendations. A 6-month review will be
conducted to look at the timeliness of reacting to recommendations to determine the effectiveness of this process.

Documentation and communication remain real challenges in patient care practice for pharmacists and other
providers. Since the passage of the American Recovery and Reinvestment Act in 2009, which contained the
Title XIII Health Information Technology for Economic and Clinical Health Act, much work has occurred to
use technology to improve documentation and communication at the federal and state level. The Pharmacy
Health Information Technology Collaborative is actively involved in pharmacy’s participation in this work, and
it is important for pharmacy practitioners to stay up-to-date with the work and documents created from this
collaborative.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-181
 Managing a Clinical Practice

IV. MEASURING THE QUALITY OF YOUR PROGRAM

Domain 4 Task 5, Domain 5 Task 1

A. Importance of Measuring the Quality of Your Services, Your Organization, and Health Care in the United States
1. The Institute of Medicine (IOM) 1999 report “To Err Is Human” brought attention to the harm being
done to patients in the health system.
a. 100,000 patients die each year because of error.
b. Medications are a major source of error.
2. Quality gap in health care
a. Quality gap is the difference between top-performing organizations and average-performing
organizations.
b. In health care, the quality gap is around 20% (NCQA 2004).
c. For other “potentially dangerous” industries, such as airline travel, the quality gap is 1%.
3. The quality ranking of the United States is around 30th in industrialized countries, yet the United
States spends the most on health care (World Health Organization 2000; Woolf 2013; JAMA
2013;310:591-608).
4. Lack of improvement, despite 13 years of focus on quality in the United States. U.S. quality rankings
have remained the same.
5. High cost of health care is driving demand for the best value/cost ratio placing emphasis on quality
measures, including the value component of the ratio.

B. Response by Payers in the Health Care System

1. U.S. government and initiation of the Triple Aim – A framework for health care improvement.
The components are as follows:
a. Better care for individuals
b. Better health for populations
c. Reducing per capita costs
2. Changing models of care that emphasize quality versus volume as drivers of payment
a. ACOs
i. Voluntary groups of physicians, hospitals, long-term care providers, and other
health care providers
ii. Assume responsibility for the care of a clearly defined population of beneficiaries assigned
to them by a payer(s) (e.g., Medicare), based on patients’ use of primary care services
iii. Shared savings. If the triple aim is met at better care and health with reduced costs, the
savings are shared between the ACO and the payer.
iv. Quality and quality measure reports on populations are a major part of the ACO goals.
b. PCMH – A new model of primary care with the following principles:
i. Comprehensive team-based care. Team members vary; however, they include a physician,
a nurse or nurse practitioner, and a patient coach as core members. Others include
pharmacists, dietitians, social workers, and physical and occupational therapists. Members
have varied widely and have included almost any health provider.
ii. Patient-centered or whole-person orientation
iii. Care that is coordinated
iv. Superb access to care. Ensuring that patients receive their desired care whenever they need it
v. Systems-based approach to quality and safety
vi. Payment reflective of care given

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-182
 Managing a Clinical Practice

C. Value-Based Purchasing Payment Models: Payment models and contracts for services that reward quality
of the services provided as opposed to the number served
1. Pay-for-performance is payment for health care services aligned with quality measures and
performance of the providers, usually through incentives or disincentives.
2. Global or capitation or global payment with quality benchmarks: A set per-patient fee paid to the
provider that encompasses the total cost of care for patients’ services during a set time interval
3. Episodes of care or bundled payment: Payment arrangements that include financial and performance
accountability for episodes of care (e.g., a set fee for a hip replacement)
4. Risk sharing
a. Full risk is when the organization and providers are at full financial risk for negative events that
increase costs such as hospitalizations.
b. Partial risk or risk sharing is when the organization and the payer share the financial risk for
negative events that increase cost. The shared percentage is usually pre-negotiated.
c. Prometheus payment is usually a capitated payment model that is continuously restructured
during a set period and is based on how the organization compares with the average quality
measure in its community or region.

D. Defining Quality
1. There is no universally accepted definition for what defines health care quality. Differences in
perspective can drive what any one individual or entity may consider as quality, resulting in layers of
complexity in attempts to define the term. The various perspectives may not be well aligned, further
contributing to the problem.
a. Patients – May primarily care how they are treated or if they feel better
b. Provider – May care about surrogate measures such as blood pressure or improvement in disease
c. Administrator – May care that services are efficient and not costly
d. Payer – May care that hospitalizations are reduced as well as other overall health care costs
2. The IOM defines quality as the degree to which health services for individuals or populations increase
the likelihood of desired health outcomes that are consistent with current professional knowledge
(IOM 1990). Although not considered a universal definition, it encompasses what many would
consider as quality.

E. Donabedian Domains to Determine and Measure Quality in Health Care. Dr. Avedis Donabedian
proposed these domains for health care quality measurement more than 25 years ago, and they still are
the foundation of quality improvement today.
1. Structure – How resources and systems affect patient care
2. Process – How provider-patient interactions and the care and services provided affect the patient
3. Outcome – What happens to patients: Further categorized by the ECHO (Extension for Community
Healthcare Outcomes) model
a. Economic outcomes
b. Clinical outcomes
c. Humanistic outcomes

F. Methods Often Used by Organizations to Evaluate Quality

1. Lean method – Focus is more on clearly defining structure and process.
a. Derived from the Toyota Motor Corporation to improve efficiency
b. Uses patient outcomes as a goal and then focuses on processes to eliminate waste or any non–
value-added activities during the process to meet the goals

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-183
 Managing a Clinical Practice

c. Purpose is to define the optimal sequence for delivery of services to achieve efficiency and quality.
d. Structure and process measurement is used to determine which components of care are critical to
producing the desired patient outcome.
2. Six Sigma – Focus is more on variations in process.
a. A method focused on reducing variation and defects within processes to consistently create
a desired outcome
b. Six Sigma is a statistical term of measurement that indicates a level of defect per 1 million
opportunities. Six Sigma represents an almost error-free process.
c. The steps in the Six Sigma process are as follows:
i. Identify and define what has to be improved.
ii. Measure by collecting data; analyze the results.
iii. Use creative solutions to improve, and then control, the process with policies, guidelines,
and strategies.
3. Plan, do, study, act cycle (PDSA cycle) – Quick and manageable process for small groups
a. This method uses three key questions.
i. What are we trying to accomplish?
ii. What change can we make that will result in improvement?
iii. How will we know that a change is an improvement?
b. Planning stage
i. Aims are established according to the outcome desired.
ii. Strategies for change are developed.
iii. Measures are chosen that will determine whether you achieved your aim.
iv. Do phase: Implement the change.
c. Study phase: The change is tested using the defined measures.
d. Act phase: Results are used from the study phase to reenter the cycle for further improvement.
4. New proposed model (Pediatrics 2013;131:S110) may be more patient centered. Actions of quality
superimposed with interpersonal tasks of the patient visit and involves the patient
a. Patient entering the system phase: Measured for quality is how well information was obtained (by
the providers) from the patient by an evaluation of the “data repository” obtained from the patient
b. Assessment of care needed for the patient phase: Measured for quality is how much the patient’s beliefs,
preferences, culture, etc., were considered by the provider by measuring the patient’s perception of
how much consideration was given to these factors and to the patient’s individual needs
c. Management plan phase: Where the plan is developed, coordinated, executed, and reassessed
i. Measure how much the patient participated in decision-making.
ii. Measure how well the patient participates in the plan, termed the patient as a partner.

G. Creating Your Program. Consider using a business concept called Balanced scorecard that states you
should not focus on only one area of your service (e.g., just patient outcomes). Doing so may result in
gains in one area but failures in the other areas; this in turn may sabotage the overall quality of your
program. For example, if you just focus on blood pressure as an outcome but do not make sure that the
staff performing blood pressure measurements are doing so correctly or that blood pressure measurement
is easily captured in your process, you may not achieve the outcome goal you desire. There are four areas
you need to measure to ensure quality.
1. Structure examples include the following:
a. Staff is adequately trained.
b. Communication systems work and are efficient.
c. Workload is manageable.
d. Employee satisfaction and retention

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-184
 Managing a Clinical Practice

2. Process examples include the following:

a. Error rates
b. Timeliness of services
c. Documentation meeting standards
d. Task performance quality measures
3. Patient outcomes. Examples include the following:
a. Clinical markers
b. Patient satisfaction (as well as other customers)
c. Care experiences
4. Financial outcomes. Examples include the following:
a. Clinic growth and referrals
b. Cost avoidance
c. Reimbursement and revenue capture
d. Cost/value ratio

H. When Choosing Measures, you should consider the following key characteristics:
1. Meaningfulness
a. The measure must be meaningful to you and your patients.
b. Measure an area known to need improvement.
2. Feasibility
a. Can you collect the data needed?
b. How disruptive will collecting data be to your workflow?
c. Do you have the resources to collect the data?
d. Will the collection and analysis be timely for action?
3. Actionable
a. You must be able to use the results you obtain.
b. Can you make the necessary changes on the basis of results?

I. Sources for Measures. More than 8000 health care quality measures are currently available, and health
care organizations in the business of measure development continue to create more measures to fill current
gaps. Many of these measures have been tested and evaluated with some rigor to ensure a level of validity
and quality. Your service may be affected by many of the measures adopted by payers and accreditation
organizations. It is important to understand measure developers, validators, promoters, and users so that
you can choose the measures most meaningful for your practice and organization. The following are
organizations working on the national stage. There are more organizations, however, that you may need to
be aware of that work in the private or state level for your community.

1. Government-related organizations
a. AHRQ
i. Sets national strategy for quality improvement in health care. See Table 1 for current national
quality priority measures important for ambulatory care pharmacists.
ii. Developed a collection of 100 evidence reports during the past 9 years titled “Closing the
Quality Gap Series”
b. National Quality Measures Clearinghouse (NQMC)
i. A public resource for evidence-based quality measures housed by AHRQ
ii. 8000 measures currently reside in the database.
iii. Measures are categorized, providing information for the user necessary to evaluate measures
for validity, importance, scientific soundness, and feasibility.
iv. Search functions are user-friendly.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-185
 Managing a Clinical Practice

c. Centers for Disease Control and Prevention

i. Healthy People 2020
ii. National Health Interview survey
d. Universal Data Set (UDS)
i. Established by HRSA (Health Resources and Services Administration) program for Health
Center Program grantees
(a) Federally qualified health centers (FQHCs)
(b) Migrant Health Centers
(c) Health Care for the Homeless
(d) Public Housing Primary care
ii. Twelve tables to report clinical, operational, and financial data including quality of care and
health outcome measures
e. Institute of Medicine (IOM)
i. An independent, nonprofit organization established under the National Academy of Sciences
ii. Role is to work outside government to provide unbiased and authoritative advice to decision-
makers and the public.
iii. Almost 200 reports on health care quality and patient safety are available.
f. Pharmacy Quality Alliance (PQA)
i. One of four quality alliances (i.e., Hospital Quality Alliance [which is responsible for the
Hospital Compare System], Ambulatory Quality Alliance, and Long-Term Care Quality
Alliance)
ii. Established as public-private partnerships to assist CMS and health care in general in
ensuring the provision of quality services to Medicare beneficiaries and all patients
iii. Workgroups consisting of multidisciplinary representatives from member organizations
develop measure concepts that are then tested, voted on, and moved forward for public use.

Table 1. 2013 National Strategy Priority Measures Important to Ambulatory Care Pharmacists
Measure Focus Measure Name/Description Baseline Rate Most Recent Rate Aspirational Target
Hospital All-payer 30-day 14.4%, based 14.4%, based on Reduce all
readmissions readmission rate on 32.9 32.7 million readmissions by 20%
million admissions in 2011 by the end of 2014
admissions
Decision-making People with a usual source 15.9% Update available Reduce to < 10%
of care whose health in fall 2013 by 2017
care providers sometimes
or never discuss decisions
with them
Aspirin use Outpatient visits in which 47% 53% Increase to 65%
adults with cardiovascular by 2017
disease are prescribed/
maintained on aspirin
BP control Adults with hypertension 46% 53% Increase to 65%
who have adequately by 2017
controlled BP
Cholesterol Adults with high cholesterol 33% 32% Increase to 65%
management under adequate control by 2017

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-186
 Managing a Clinical Practice

Table 1. 2013 National Strategy Priority Measures Important to Ambulatory Care Pharmacists (continued)

Measure Focus Measure Name/Description Baseline Rate Most Recent Rate Aspirational Target
Smoking Outpatient visits in which 23% 22% Increase to 65%
cessation current tobacco users receive by 2017
tobacco cessation counseling
or cessation medications
Depression Percentage of adults reporting 68.2% 68.1% for 2011 Increase to 78.2%
symptoms of a major by 2020
depressive episode in the
past 12 mo who receive
treatment for depression in
the past 12 mo
Obesity Proportion of adults 35.7% Update available Reduce to 30.5%
with obesity in 2014 by 2020
BP = blood pressure.
Adapted from: Agency for Healthcare Research and Quality (AHRQ). 2012 National Healthcare Quality Report. AHRQ Publication No.
13-0002. Rockville, MD: U.S. Department of Health and Human Services, May 2013. Available at www.ahrq.gov/workingforquality/nqs/
nqs2012annlrptapa.htm. Accessed February 14, 2014.

g. Quality improvement organizations

i. Independent organizations contracted with CMS to improve the effectiveness, efficiency,
economy, and quality of services delivered to Medicare beneficiaries
ii. Located in every state
iii. Work to monitor, educate, and assist providers and patients in the delivery and receipt of
quality services
iv. Have scope-of-work contracts with CMS to focus on certain outcomes. Current 10th scope of
work has the following focus:
(a) Patient and family engagement
(b) Reduction in hospital readmissions by 20%
(c) Reduction in adverse drug events
(d) Disease prevention through improved screening and immunizations
(e) Prevention of cardiovascular disease
h. Alliance for Integrated Medication Management Collaborative (formerly PSPC [Patient Safety
and Clinical Pharmacy Services Collaborative])
i. Initiated by the Health Resources and Services Administration (HRSA) in 2007 to address
adverse medication events for uninsured, isolated, or medically vulnerable patients serviced
by “safety-net” providers such as FQHCs
ii. Uses the PDSA process to integrate clinical pharmacy services in patient care settings to
improve patient safety and health outcomes
iii. Membership has expanded to include any multidisciplinary, community-based group with
high-risk patients that has integrated or that can integrate clinical pharmacist services.
iv. In 2014, became an independent nonprofit organization
v. Focus of quality measurement has been on diabetes, hypertension, hyperlipidemia, and
adverse drug events.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-187
 Managing a Clinical Practice

i. National Quality Forum

i. Created in 1999 by a Presidential Commission to review health care quality and consumer
protection
ii. Measure endorsement is primary role. Criteria for approval are as follows:
(a) Be in the public domain.
(b) Be fully tested for reliability and validity.
(c) Have importance, scientific merit, feasibility, and usability compared with competing
similar measures.
iii. Endorsed measures are easily found within the NQMC database.
2. Accreditation organizations
a. NCQA
i. Founded in 1979 by the managed care industry to review PPO (preferred provider
organization) plans and HMOs (health maintenance organizations)
ii. “Reestablished” itself in 1990 as a private, independent nonprofit health care quality
oversight organization
iii. Developed the Healthcare Effectiveness Data and Information Set (HEDIS) measures for
employers to evaluate the health plans they use for employee benefits
(a) Providers who contract with these health plans are responsible for meeting the
applicable measures.
(b) A significant portion of the 2014 HEDIS measures revolve around medication use and the
patient care work of pharmacists in the ambulatory care setting.
iv. Provides accreditation, certification, and recognition programs
(a) ACO accreditation
(b) PCMH recognition
(c) Diabetes management recognition program
b. CPPA
i. Established in 2012 through the efforts of the American Pharmacists Association, the National
Association of Boards of Pharmacy, and the American Society of Health-System Pharmacists
ii. Initial accreditation program offered by CPPA is for community pharmacy practice.
iii. Plans to cover the complete ambulatory practice arena
c. Utilization Review Accreditation Commission (URAC)
i. Grew out of the utilization review industry
ii. Provides a wide variety of accreditation programs
(a) ACO accreditation
(b) PCMH achievement
(c) Drug therapy management accreditation
(d) Mail service pharmacy accreditation
(e) Pharmacy benefit management accreditation
(f) Specialty pharmacy accreditation
(g) Community pharmacy accreditation
d. Joint Commission: Offers accreditation for medical practices and a certification for primary care
medical homes
3. Payers: Medicare
a. Physician Quality Reporting System (PQRS)
i. 310 measures
ii. A voluntary program up to 2014 with attached financial incentives for eligible Part B
providers to select and report to CMS on a subset of self-chosen measures
iii. In 2015, PQRS will be a mandatory program, with payment disincentives for those who do
not participate.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-188
 Managing a Clinical Practice

b. Five-star quality rating programs

i. Medicare Part C and Part D plans
ii. Fifty measures to evaluate the performance and quality of services of the participating
plans to assist beneficiaries in choosing the best plans and in determining payment and
participation in Medicare
iii. Five medication measures developed by PQA on medication adherence and high-risk
medication use in the elderly, composing 50% of the plan’s score because of their importance
and assigned weighting among all the measures. (Note: The measure for appropriate blood
pressure measure in people with diabetes is retired as of 2016 based on the JNC 8 [Eighth
Joint National Committee] recommendations.)
iv. One process measure, Medication Therapy Management Program Completion Rate for
Comprehensive Medication Reviews for Medicare Part D plans, will be added at a weight of
one (not an elevated weight because it is a process measure, not an outcome measure).
c. Meaningful-use measures
i. Reporting of clinical quality measures is a requirement.
ii. Measures, based on national priorities, include morbidity and mortality of beneficiaries,
conditions of disproportionate cost
iii. Medicare Part B–eligible providers must report at least 3 months of data on 9 of the 64
approved measures that cover at least three of the national priority domains.
d. CMS hospital readmissions reduction program
e. Medicare Shared Savings Program as an ACO
i. Report on 33 performance measures
(a) Four domains (Table 2)
(b) Twenty-three of the 33 measures are medication related (Table 3).
ii. Measures may be changed and updated yearly.

Table 2. Domains for ACO Measures

No. of Total Domain
Domain Individual Total Measures for Scoring Possible Weight,
Measures Points %
Patient/caregiver
7 Seven individual survey module measures 14 25
experience
Care coordination/ Six measures, plus the EHR measure
6 14 25
patient safety double weighted (4 points)
Preventive health 8 Eight measures 16 25
Seven measures, including five-component
diabetes composite measure and two-
At-risk population 12 14 25
component coronary artery disease
composite measure
Total in all domains 33 28 58 100
EHR = electronic health record.
Information from: Centers for Medicare & Medicaid Services. Medicare Shared Savings Program Quality Measure Benchmarks for the 2014 and
2015 Reporting Years. Available at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/sharedsavingsprogram/Downloads/
MSSP-QM-Benchmarks-2015.pdf. Accessed September 15, 2015.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-189
 Managing a Clinical Practice

Table 3. Examples of ACO Measures Pharmacist Patient Care Services May Affect
Domain Measures
Patient/caregiver experience Shared decision-making
Health status/functional status
Care coordination/patient safety Hospital readmissions
Medication reconciliation
Preventive health Influenza immunization
Pneumococcal immunization
Smoking cessation
At-risk population Diabetes - Hemoglobin A1C control
Hypertension – BP control
Heart Failure – β-Blocker for LVSD
Hyperlipidemia – Appropriate management
Coronary artery disease – ACE and ARB therapies
Ischemic vascular disease – Use of aspirin or another antithrombotic
ACE = angiotensin-converting enzyme inhibitor; ACO = accountable care organization; ARB = angiotensin receptor blocker; LVSD = left
ventricular systolic dysfunction.
Information from: Centers for Medicare & Medicaid Services. Medicare Shared Savings Program Quality Measure Benchmarks for the 2014
and 2015 Reporting Years. Available at www.cms.gov/Medicare/Medicare-Fee-for-service-Payment/sharedsavingsprogram/Downloads/
MSSP-QM-Benchmarks.pdf. Accessed December 31, 2014.

4. Professional organizations and collaboratives

a. Institute for Healthcare Improvement (IHI)
b. Patient-Centered Primary Care Collaborative (PCPCC)
c. Physician Consortium for Performance Improvement (PCPI)

J. Challenges to Using Quality Measures

1. Attribution. The ability of the quality measure to describe the quality of a particular provider,
team, organization, etc.
2. Statistical accuracy and sampling. Most measures have not gone through the scientific rigors of
research-based evaluations to assure the results are statistically accurate or what minimal sample
is needed for accuracy.
3. Accounting for exceptions. Because not all patients are alike, there will be situations where the most
appropriate care is contrary to the measure. A determination needs to be made of what percentage is
considered an acceptable exception rate and how providers and organizations are protected when they
deviate from a selected measure when it is the correct patient decision.
4. Risk adjustment. It is well known that for certain populations, the goals of any particular measure
may be more difficult to achieve. How is that accounted for in the measures chosen for your
organization? Many measures do not have risk adjustment specifications. Creating a situation where
organizations may refuse to accept those patients who may place them at financial risk
5. Appropriate benchmarks. Current measures are often targeted to one topic that may not reflect the
health of the patient. Are we measuring what matters to patients? Is that what we should be measuring?
6. Potential for gaming. Gaming refers to documentation that an outcome is achieved, but in reality, the intent
of the outcome did not occur at the patient level. This potential should be a consideration when choosing
measures, and it is more problematic with process measures. For example, a check box can indicate that
counseling was provided to exercise 30 minutes 5 days a week and lead to a value-based payment. If the
patient did not or could not act on the counseling, should that provider be rewarded with payment?
7. Gaps in measures. Despite the many measures in the marketplace, significant gaps remain in needed
measures. Examples of gaps are measures that assess cost, affordability, and patient engagement.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-190
 Managing a Clinical Practice

K. The Call to Measure What Matters to Patients. IOM Vital Signs: Core Metrics for Health and Health Care
Process (http://iom.nationalacademies.org/Reports/2015/Vital-Signs-Core-Metrics.aspx)
8. Are your patients getting better?
9. Are your patients’ opinions, concerns, health care desires respected?
10. Are you causing harm to your patients?
11. Do your patients consider the care you provide accessible, available, and affordable?

L. IOM Suggested Core Measures: For health care in the United States to improve, there needs to be a set of
measures that the entire enterprise can work, that are meaningful to all patients, and that can be affected
by health care providers. The IOM has challenged each stakeholder in health care, from the Department
of Health and Human Services to each individual practitioner, to determine which of the following core
measures and priorities they can affect. The IOM has also recommended that leaders in health care adopt
these measures. Although the priority measures listed may not be optimal, they were determined to be the
best available at this time. The measure listed first under the core measure focus is considered the best of
current measures. The others listed are considered related priority measures.
1. Healthy people
a. Life expectancy
i. Infant mortality
ii. Maternal mortality
iii. Violence and injury mortality
b. Well-being
i. Self-reported health
ii. Multiple chronic conditions
iii. Depression
c. Overweight and obesity
i. Body mass index
ii. Activity levels
iii. Healthy eating patterns
d. Addictive behavior
i. Addiction death rate
ii. Tobacco use
iii. Drug dependence/illicit use
iv. Alcohol dependence/misuse
e. Unintended pregnancy
i. Teen pregnancy rate
ii. Contraceptive use
f. Healthy communities
i. High school graduation rate
ii. Childhood poverty rate
iii. Childhood asthma
iv. Air quality index
v. Drinking water quality index
2. Care quality
a. Prevention
i. Childhood immunization rate
ii. Influenza immunizations
iii. Colorectal cancer screening
iv. Breast cancer screening

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-191
 Managing a Clinical Practice

b. Access to care
i. Unmet care need
ii. Usual source of care
iii. Delay of needed care
c. Safe care
i. Hospital-acquired infection rate
ii. Wrong-site surgery
iii. Pressure ulcers
iv. Medication reconciliation
d. Appropriate treatment
i. Preventable hospitalization rate
ii. Cardiovascular risk reduction
iii. Hypertension control
iv. Diabetes control composite
v. Heart attack therapy protocol
vi. Stroke therapy protocol
vii. Unnecessary care composite
e. Person-centered care
i. Patient-clinician communication satisfaction
ii. Patient experience
iii. Shared decision-making
iv. End-of-life/advanced care planning
3. Care cost
a. Affordability
i. High spending relative to income
ii. Health care–related bankruptcies
b. Sustainability
i. Per capita expenditures on health care
ii. Total cost of care
iii. Health care spending growth
4. Engaged people
a. Individual engagement
i. Health literacy rate
ii. Involvement in health initiatives
b. Community engagement
i. Social support
ii. Availability of health food
iii. Walkability
iv. Community health benefit agenda

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-192
 Managing a Clinical Practice

V. ENSURING THE CONTINUED COMPETENCY OF YOUR STAFF

A. Domains of Competency
1. Information competency
a. Base knowledge needed for your practice
b. Self-directed learning; ability and drive to keep up with literature and new knowledge
c. Ability to apply your knowledge to patient care
d. Willing to seek out information when it is not known
e. Wisdom in decisions in unclear or challenging situations
2. Communication competency
a. Compassion as a driver of patient care
b. Empathy as a driver in patient care
c. Self-control in challenging situations
d. Kindness to patients, caregivers, and coworkers
e. Influence on patients, other providers, and coworkers so that patients receive optimal care to
produce optimal outcomes
3. Character competency
a. Honesty and integrity
b. Humility
c. Takes responsibility
d. Motivated to provide best service possible
e. Moral courage to do what is right, even if it is difficult
B. Processes to Ensure Competency
1. Determine the minimum or desired training needed to perform the job at hand.
a. Level of base degree or licensure
b. Level of postgraduate training, if desired
c. Level of experience that may offset other requirements
d. Certification required or desired – There are many certifications; some have greater recognition
than do others in practice. Listed are the certifications most commonly recognized.
i. Board Certified Pharmacotherapy Specialist (BCPS)
ii. Board Certified Ambulatory Care Pharmacist (BCACP)
iii. Other
(a) Pediatric
(b) Psychiatric
(c) Oncology
(d) Added qualifications: Cardiology, infectious diseases
iv. Certified Diabetes Educator (CDE)
v. Board Certified Advanced Diabetes Management (BC-ADM)
vi. Immunization certification
vii. Other (i.e., anticoagulation, asthma, pain, smoking cessation). Before deciding to obtain
a particular certification, due diligence in ascertaining the quality and recognition of the
certification should be performed.
2. State laws or payer stipulations on credentials and training
a. Immunization certification
b. New Mexico – Pharmacist-clinician: Requires that additional physical assessment training and
150 hours/300 patient contact preceptorship be supervised by a physician or other practitioner
with prescriptive authority

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-193
 Managing a Clinical Practice

c. North Carolina – Clinical pharmacist practitioners: Must complete an application with credentials
and all the physicians’ signatures with whom they will be collaborating. Must be approved by the
Board of Medicine and the Board of Pharmacy
d. California – APPs (advanced practice pharmacists): Requires the attainment of certification in
a relevant practice area, a postgraduate residency, and 1 year of service under a collaborative
practice agreement or protocol
e. Iowa, Florida, Minnesota, Montana, and Ohio require completion of training requirements to
participate in state programs for the provision of services.
3. Ensuring maintenance of competency
a. Credentialing is a process to ensure or validate that the pharmacist (or health professional) has the
credentials, experience, or demonstrated ability and the license to be granted practice rights and
responsibilities in an organization.
b. Privileging is the granting of approval to perform a set of services within the providers’ scope of
practice in the organization.
c. Methods for recredentialing and privileging
i. Required to perform a certain number of services during a certain period for which they are
credentialed and/or privileged in providing
ii. Quality evaluation of the services provided by a provider
iii. Peer review of a subset of the services provided
iv. Continued education in areas that are credentialed and privileged during a time interval

Practice Case 3

The practice is beginning to appreciate the skill set and level of services provided by the pharmacy practice faculty,
students, and residents. The medical director approaches you about expanding your services to assist in improving
the pay-for-performance–related quality measures the practice must report. Because the population of the practice
is primarily fee-for-service, Medicare meaningful-use and PQRS measures are its primary focuses. The practice is
also seeking NCQA PCMH status. The director, who noted the student resources at the clinic, would like to explore
using students to help identify patients not meeting the medication-related measure goals and establish standard
pharmacy interventions to improve the measures. You recognize this as a good opportunity for students to learn
and participate in a pharmacist-based role as well as an opportunity for scholarship. You engage one of the tenure-
track faculty members to assist you in developing the project as well as a research protocol to study the outcomes
of pharmacy students and pharmacists assisting in measure and pay-for-performance attainment in a primary care
office. Your college is struggling to identify suitable ambulatory experience sites for students, and this opportunity
may enable you to take an additional student for each rotation.

The training of future pharmacists is important for all practitioners to consider as part of their professional
responsibility. This case is an example of a win-win situation where students can learn about ambulatory practice
and also provide needed services to the organization at minimal expense.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-194
 Managing a Clinical Practice

VI. REIMBURSEMENT FOR PHARMACIST SERVICES IN THE AMBULATORY SETTING

Domain 4, Task 2
A. Potential Payers for Pharmacist Services
1. Federal government and Medicare services
a. Medicare Part A
i. Governs services from hospitals, health systems, long-term care facilities, and hospice
and home health services
ii. Benefit available for all eligible beneficiaries
b. Medicare Part B
i. Governs medically necessary outpatient services
ii. Covers services provided by those with Medicare Part B provider status. Those with Medicare
Part B provider status are physicians and other non-physician providers listed below:
(a) Anesthesiology assistants and certified registered nurse anesthetists
(b) Audiologists
(c) Certified nurse midwives
(d) Clinical nurse specialists and nurse practitioners
(e) Clinical psychologists
(f) Clinical social workers
(g) Individuals who provide mass immunization
(h) Physical and occupational therapists in private practice
(i) Physician assistants
(j) Registered dietitians or nutrition professionals
(k) Speech-language pathologists
iii. Covers some preventive services (immunizations) and some home care services
iv. Not available to those without Social Security benefits
v. Eligible beneficiaries may opt out of having this benefit; therefore, not every Medicare
patient has this coverage.
c. Medicare Part C or Medicare Advantage
i. A Medicare health plan offered by a private company that contracts with Medicare to provide
Part A and Part B benefits. Many plans also provide Part D benefits. Medicare pays a fixed
amount for each beneficiary each month to the companies. Part C must provide benefits that
are at least equivalent to those of traditional Part A and Part B; however, more benefits may
be offered as well.
ii. Beneficiary choice of this model may grow with the implementation of the new models of care.
iii. Beneficiaries opt to join.
d. Medicare Part D – Prescription benefits
i. Administered by commercial payers or prescription drug plans (PDPs)
ii. Houses MTM services
iii. Beneficiaries opt to join.
2. Private organizations
a. Commercial insurers
b. Self-insured employers or employer groups
3. State-run programs
a. Medicaid
b. Insurance exchanges
4. Self-pay

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-195
 Managing a Clinical Practice

B. Barriers to Billing for Services

1. Understanding reimbursement terminology and language
a. HCPCS (Healthcare Common Procedure Coding System) codes
i. Healthcare Common Procedure Coding System
ii. Two levels
(a) Level 1 – Current procedural terminology (CPT) codes
(b) Level II – Codes for product supplies and services not covered under CPT (e.g.,
ambulance, durable medical equipment). Codes range from A to V alphanumeric codes.
Examples include G codes, which are classified as temporary procedures and professional
services and include diabetic education codes; and J codes, which are codes for drugs
administered other than oral method and are often used in outpatient infusion clinics.
b. CPT codes
i. Set of medical nomenclature used to report medical procedures and services to public and
private health insurance programs
ii. Maintained and owned by the American Medical Association (AMA)
c. E/M codes
i. Five-digit CPT codes that start with 99; describe services related to physician visits in the
ambulatory setting
ii. Documentation requirements for these codes are discussed above in the Documentation section.
d. RBRVS (resource-based relative value scale)
i. Standardized reimbursement model created as a standardized method of analyzing resources
involved in the provision of health care services or procedures
ii. Considers the following factors:
(a) Physician work or the complexity and difficulty of the procedure or visit
(b) Practice expense
(c) Liability insurance
iii. A relative value unit (RVU) is assigned to each CPT code; this determines the final payment
a provider will receive for that code.
iv. RVUs are determined yearly by an AMA committee; must be budget neutral
v. RVUs are adjusted according to GPCIs (geographic practice cost indexes) and the SGR
(sustainable growth rate). Pharmacists billing incident-to (below) will see the impact of
RVUs on the different reimbursement rates for the codes around the country.
vi. MTM codes do not have RVUs.
e. ICD-9/ICD-10 codes
i. Stands for International Statistical Classification of Diseases and Related Health Problems
(i.e., disease and condition codes)
ii. Always required in billing for justification of services
iii. Medicare is in the process of converting to ICD-10 as of October 1, 2015.
iv. ICD-10 codes are replacing ICD-9 codes because of needed improvements, and the ICD-9
structure is running out of numbers needed to document medical conditions.
v. ICD-10 differs from ICD-9 as follows:
(a) Code numbers available in ICD-10 are 69,000, as large increase from ICD-9 which had a
total of 13,600 to 69,000.
(b) All codes are alphanumeric for ICD-10; they begin with a letter and a mix of letters and
use numbers thereafter.
(c) ICD-10 code lengths vary from four to seven digits.
(d) New codes provide more clarity with respect to what is being treated.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-196
 Managing a Clinical Practice

f. Medicare Administrative Contractors (MACs) – In the past, also called fiscal intermediaries or
Part B carriers. MACs are private companies contracted with Medicare to administer Medicare
funds to providers. Moreover, MACs provide reimbursement services, medical coverage
review, and audits; respond to provider inquiries; educate providers; establish local coverage
determinations; and process claims. Currently, there are 12 Medicare Part A/B MACs and 4
Durable Medical Equipment (DME) MACs.
g. Health Care Financing Administration 1500 form (HCFA 1500)
i. The official standard form used by individual health care providers (e.g., physicians, nurse
practitioners) when submitting bills or claims for reimbursement to payers
ii. Primarily a federal government form, but used universally
h. Uniform billing (UB) 92 (old) and the updated UB-04 also called the CMS-1450 (new)
i. Form used by facilities or institutions (e.g., hospitals, long-term care facilities) when
submitting bills
ii. Government payers use UB-04, but some private payers may still use UB-92.
i. National Provider Identifier (NPI) is self-explanatory, and pharmacists may apply and receive.
Must have NPI for electronic billing
j. Medical necessity. The services you provide must be deemed medically necessary. CMS defines
“medically necessary” as “services or supplies that are proper and needed for the diagnosis or
treatment of a medical condition and are provided for the diagnosis, direct care, and treatment of
the medical condition, meet the standards of good medical practice in the local area, and are not
mainly for the convenience of the patient or the provider” (www.medicare.gov/glossary/m.html).
2. Rules and regulations are constantly changing with frequent updates. These are generally sent to the
billing and coding personnel. It may be difficult to try to keep up with them yourself. Instead, develop
relationships with those responsible for billing in the organization so that you stay informed.
a. Medical billing companies or organizations
b. Compliance officer – Person within an organization responsible for ensuring compliance with
payers, regulators, contractors, and accreditors
c. Office manager
d. You can connect with the Medicare Learning Network and sign up for their e-newsletter and
other resources (www.cms.gov/Outreach-and-Education/Outreach-and-Education.html).

C. Medicare Rules for Billing – By law, Medicare beneficiaries must be billed usual and customary prices.
This means that a provider cannot discriminate against Medicare patients in billing or give another group
of patients a substantially cheaper rate for the same service. Consequently, most organizations will follow
Medicare rules for all patients (non-Medicare patients) unless there are specific state rules for state-run
programs or unless there is an existing contractual relationship that dictates a different process with
commercial payers.

D. Institutional Billing Options for Pharmacists – Medicare Governed by the Hospital Outpatient Prospective
Payment System (HOPPS)
1. “Facility fee” billing
a. Typically used for non–Medicare B-recognized providers who are employed, contracted, or
leased by the institution
b. Essentially pays the hospital the costs of using the facility to provide services to the beneficiary
c. Before 2014, CPT codes were converted to APC codes (Ambulatory Payment Classification
system – a coding system housed under HCPCS II).
d. APC was established as a method of paying for facility outpatient services; it is analogous to the
way in which inpatient services or DRGs (diagnosis-related groups) are paid.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-197
 Managing a Clinical Practice

e. In 2014, new HOPPS regulations created one APC code to cover all hospital outpatient visits
(known as APC 0634 – note: now an old APC code).
f. In 2015, CMS changed the APC code to 5012.
2. Requirements for facility fee billing
a. Medically necessary
b. Sufficiently documented
c. Established patient (seen within the past 3 years)
d. Meet incident-to rule requirements – See item 6 in Table 4. The supervising provider must be in
the building where the incident-to services are being performed.
e. In 2014, CMS changed billing for these services to HCPCS II code G0463 and one set fee.
This replaces the use of E/M CPT codes 99201–99205 (new patient visit) and 99211–99215
(established patient visit), which had a range of fees that could be used.
f. When billing the facility fee as of 2015, the APC code 5012 is used together with the
HCPCS II G0463 code.
3. Barriers for facility fee billing
a. Copayment for the patient for Medicare
b. May be lumped into deductibles for commercial payers

E. Clinic or Physician Office Billing Options for Pharmacists – Medicare

1. Incident-to billing is an indirect billing mechanism whereby auxiliary personnel under their scope
of practice may provide patient care services under the direct supervision of a physician or other
approved Medicare Part B provider (physician, physician assistant, nurse practitioner, clinical nurse
specialist, nurse midwife, or clinical psychologist). The service must be a necessary service that is
under and integral to the service provided by the approved Medicare Part B provider. Medicare Part B
pays for management for medical conditions or problems; it does not pay for medication management,
which CMS considers a Part D benefit.
2. Requirements for incident-to billing
Patient must be established with the practice (seen in the practice within the past 3 years).
a. Must have a face-to-face visit with the physician before the incident-to visit
b. Service must be medically necessary.
c. Service is an integral, although incidental, part of the physician’s service.
d. Service is commonly provided in the physician’s office.
e. Service is part of the physician’s bill.
f. Must be provided under direct supervision by the physician (physician must be present in
the office space)
g. The physician must be actively involved by continuing to have face-to-face visits and E/M of
the problem associated with the incident-to billing. There are no hard and fast rules on frequency,
but the industry often suggests the one-in-three rule or physician sees patient every third visit.
h. The service provided must be within the state scope of practice of the auxiliary personnel.
i. Meet all the requirements listed in Table 4
3. Levels of billing
a. Five levels (Table 3)
b. Specifics of the required elements outlined in Medicare E/M 1997 regulations

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-198
 Managing a Clinical Practice

Table 4. Medicare Requirements for Incident-to Billing

1. Before the pharmacist can provide an incident-to service, the patient must have been seen by the physician
or other Medicare Part B–approved practitioner for the same problem; the provider must have provided an
evaluation or a Medicare-covered service
2. The physician or Medicare Part B–approved provider must have provided authorization for the service,
and the authorization must be included in the medical record
3. The physician or Medicare Part B–approved provider must provide subsequent services at a frequency
that reflects his or her active participation in managing the course of treatment; review of the medical
record does not qualify
4. The service is of the type commonly furnished in a physician or Medicare Part B–approved provider’s
office or clinic
5. The service must be medically appropriate to be provided in the provider’s office or clinic
6. A physician or Medicare Part B–approved practitioner must be on the premises, but not necessarily in the
room, when incident-to services are performed; the supervising practitioner must be part of the organiza-
tion defined as performing Medicare-billable services for patients within the organization; the supervis-
ing physician need not be the same physician or other practitioner whose professional service serves as a
basis for the incident-to service
7. The pharmacist providing the incident-to service must be an employee, leased or contracted to the physi-
cian, or a Medicare Part B–approved provider; the practice must have some legal control over the person
and his or her services, and the person must represent an expense to the practice

4. Incident-to billing and pharmacist-specific rules and interpretations

a. Pharmacists are considered auxiliary personnel; therefore, they can bill under incident-to rules.
b. Billing at levels higher than 99211 is determined by state scope of practice. MACs have historically
used their ability to establish local coverage determinations to weigh in on what level pharmacists
can bill. However, the 2016 Physician Fee Services rules from CMS provide clarification in the
background section regarding this issue: “the supervising provider should bill and get paid for
incident-to services provided by auxiliary personnel just as if the supervising provider were
personally providing the service.” This would suggest that as long as incident-to rules are met and
the service is within the pharmacist’s state scope of practice for pharmacy, pharmacists should be
able to bill the range of incident-to codes that describe their services and that have documentation
supporting the code chosen to be billed.
c. MTM cannot be billed under incident-to codes because MTM is a Part D benefit, not a Part B benefit.

F. Special Billing Situations Available for Pharmacists – Medicare

1. Diabetes education G codes
a. G0108 – Individual visits
b. G0109 – Group visits (two patients or more)
c. Billed and paid in 30-minute increments
d. Requires a physician order that states the following:
i. Initial and follow-up hours needed (maximum of 10 hours/year)
ii. Topics to be covered
iii. Whether patient should receive individual or group training
e. To bill Medicare, must be a certified American Association of Diabetic Educators, American
Diabetes Association, or Indian Health Service program (other payers may not require certification)

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-199
 Managing a Clinical Practice

Table 5. Incident-to Billing Levels and Number of Element Requirements of Visita,b

Incident-to
99211 99212 99213 99214 99215
Level
Expanded
Visit focus N/A Problem focused Detailed Comprehensive
problem focused
HPI elements N/A 1–3 1–3 ≥4 ≥4
Includes
ROS elements N/A N/A 2–9 10–14
pertinent
2 of 3 or 3 of
PFSH elements N/A N/A N/A Pertinent
3 elements
Two elements
PE elements N/A 1–5 6–11 ≥ 12 from nine
systems
Usual length of
5 10 15 25 40
visit (minutes)
Level of
N/A Straightforward Low Moderate High
decision-making
aMedicare Benefit Policy Manual. Chapter 15. Covered Medical and Other Health Services. Available at https://www.cms.gov/Regulations-and-
Guidance/Guidance/Manuals/downloads/bp102c15.pdf. Accessed January 15, 2014.
bCenters for Medicare & Medicaid Services (CMS). 1995 Documentation Guidelines for Evaluation and Management Services. Available at
www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNEdWebGuide/Downloads/95Docguidelines.pdf. Accessed
January 15, 2014.
HPI = history of present illness; N/A = not applicable; PE = physical examination; PFSH = past, family and social history; ROS = review of systems.

2. CMS annual wellness visits (AWVs)

a. HCPC II codes
i. G0402 (initial preventive physical examination)
ii. G0438 (initial AWV, once in lifetime)
iii. G0439 (subsequent visits, AWV)
b. Initial preventive physical examination (welcome to Medicare physical examination) – Done by
a physician or non-physician practitioner (not a pharmacist)
c. Bill only under Medicare Part B.
d. Will pay either the practitioner or the facility for furnishing the visit
e. Who is eligible to provide AWVs?
i. A physician
ii. Non-physician practitioners: Physician assistant, nurse practitioner, clinical nurse specialist
iii. “Medical professional” defined as a health educator, registered dietitian, nutrition
professional, or other licensed practitioner or a team of such medical professionals, working
under the direct supervision of a physician
f. Initial AWV includes 10 to-do’s:
i. Establishment of an individual’s medical/family history
ii. Establishment of a list of current providers and suppliers that are regularly involved in
providing medical care to the individual
iii. Measurement of an individual’s height, weight, body mass index (or waist circumference, if
appropriate), blood pressure, and other routine measurements, as deemed appropriate, based
on the beneficiary’s medical/family history

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-200
 Managing a Clinical Practice

iv. Detection of any cognitive impairment the individual may have, as defined in this section
v. Review of the individual’s potential (risk factors) for depression, including current or past
experiences with depression or other mood disorders, based on the use of an appropriate
screening instrument for individuals without a current diagnosis of depression, which the
health professional may select from various available standardized screening tests designed
for this purpose and recognized by national medical professional organizations
vi. Review of the individual’s functional ability and level of safety. This may be based on direct
observation, use of appropriate screening questions, or a screening questionnaire selected
by the health professional, who may select from various available screening questions
or standardized questionnaires designed for this purpose and recognized by national
professional medical organizations.
vii. Establishment of a written screening schedule for the individual, such as a checklist for the
next 5–10 years, as appropriate, based on recommendations of the U.S. Preventive Services
Task Force (USPSTF) and the Advisory Committee on Immunization Practices (ACIP),
as well as the individual’s health status, screening history, and age-appropriate preventive
services covered by Medicare
viii. Establishment of a list of risk factors and conditions for which primary, secondary, or tertiary
interventions are recommended or are under way for the individual, including any mental
health conditions or any such risk factors or conditions that have been identified through an
initial preventive physical examination, and a list of treatment options and their associated
risks and benefits
ix. Furnishing of personalized health advice to the individual and a referral, as appropriate, to
health education or preventive counseling services or programs aimed at reducing identified
risk factors and improving self-management, or community-based lifestyle interventions
to reduce health risks and promote self-management and wellness, including weight loss,
physical activity, smoking cessation, fall prevention, and nutrition
x. Any other element(s) determined appropriate by the Secretary of Health and Human Services
through the National Coverage Determination
g. Subsequent wellness visits: Depression and functional status screening are no longer required
for the visit.
h. As of 2016, CMS will pay a Part B practitioner or a facility for AWV, thus allowing hospitals to
provide this service under HOPPS.
3. Incident-to visits – Transitional care management
a. CPT E&M codes
i. 99496 (seen within 7 days of discharge)
ii. 99495 (seen within 14 days of discharge)
b. May be billed by physicians or qualified non-physician providers of care management for
discharges from the following:
i. Inpatient hospital setting (including rehabilitation and psychiatric institutions)
ii. Observational setting (less than 48-hour inpatient stay)
iii. Skilled nursing facility
c. Must be discharged to a community setting (home or assisted living)
d. Bundle face-to-face and non–face-to-face coordinated activities into one payment.
e. Face-to-face interview must be done by a Medicare-recognized qualified provider; the non–face-
to-face interview can be done by a provider working within the scope of his or her practice.
f. Pharmacists may do non–face-to-face interviews and coordination of activities and may assist the
physician or other Medicare-recognized provider during the face-to-face visit.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-201
 Managing a Clinical Practice

g. Must follow incident-to rules; however, in 2015, CMS relaxed the rule of direct supervision to
general supervision by the Medicare Part B provider for auxiliary services (includes pharmacists)
for the non–face-to-face coordinated activities with transitions of care. The face-to face services
remain under direct supervision. General supervision is defined as a direct oversight relationship
between the supervising practitioner and the clinical staff who provide after-hours services.
h. Must bill at 30 days post-discharge, not on date of visit(s)
i. Required components for billing
i. Communication with patient or caregiver within 2 days of discharge
ii. Face-to-face visit within either 7 or 14 days
iii. Complexity of medical decision-making (moderate or high)
(a) Required documentation
(b) Date of discharge
(c) Date of interactive contact with patient or caregiver
(d) Date of face-to-face visit
iv. Complexity of medical decision-making (moderate or high)
j. Components of service that may be furnished by physicians or other Medicare-recognized
providers
i. Obtaining and reviewing discharge information
ii. Reviewing the need for follow-up on pending diagnostic tests and treatment
iii. Interacting with other health care providers (specialists) who will assume or reassume care of
the beneficiary
iv. Providing education
v. Establishing or reestablishing referrals and arranging needed community resources
vi. Assisting in scheduling any required follow-ups with community providers and services
k. Components of service that may be furnished by non–Medicare-recognized health care providers
i. Communicating with agencies and community services used by the beneficiary
ii. Providing education to support self-management, independent living, and activities of daily living
iii. Assessing and supporting treatment regimen adherence and medication management
iv. Identifying available community and health resources
v. Assisting the beneficiary and/or family in accessing needed care and services
l. Cannot be billed under Part A or HOPPS
4. Incident-to visits for chronic care management (CCM) – CMS, in efforts to support primary care and
recognize CCM as a critical component of primary care, has created initiatives to improve payment for,
and encourage long-term investment in, CCM. Billable service available to providers January 2015
d. CPT code 99490 CCM requirements for billing
iv. At least 20 minutes of qualified staff time directed by a physician or other qualified health
care provider, per calendar month
v. Beneficiary or patient requirements
(d) Multiple (two or more) chronic conditions
(e) Chronic conditions expected to last at least 12 months, or until the death of the patient
(f) Chronic conditions place the patient at significant risk of death, acute exacerbation/
decompensation, or functional decline.
vi. A comprehensive care plan is established, implemented, revised, or monitored.
vii. As noted with transitional care management, CMS provides an exception to incident-to rules
of general versus direct supervision and states that the auxiliary personnel need not be a
direct employee.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-202
 Managing a Clinical Practice

e. Additional rules
iv. Copayment from beneficiary required
(d) For dual-eligible patients, state Medicaid is required to pay the copayment.
(e) For patients with private Medicare supplement insurance, the insurance is required to pay
the copayment.
(f) For patients with a secondary to Medicare full health care insurance plan (e.g., employer-
based plan), the insurance is not required to pay the copayment.
v. Practice must inform beneficiary of CCM services and obtain his or her written agreement to
have services provided and authorization for electronic communication of health information
with other providers for care coordination.
vi. Provide beneficiary a written or electronic copy of the care plan.
vii. Inform the beneficiary of the right to stop the CCM services at any time effective at the end
of a calendar month.
viii. Only one practitioner can furnish and be paid for these services during the calendar month
service period.
f. Required scope-of-service elements
iv. Patient must have access to the practice 24 hours a day, 7 days a week to CCM services (can
be provided anytime during the day). The patient must be provided a means to make timely
contact with health care providers in the practice to address the patient’s urgent chronic care
needs. Available enhanced opportunities for communication
(d) Secure messaging
(e) Telephone access
(f) Internet
(g) Other asynchronous non–face-to-face consultation methods
v. Continuity of care with a designated practitioner or member of the care team with whom the
patient can obtain successive routine appointments
vi. Includes a systematic assessment of the following:
(d) Patient medical, functional, and psychosocial needs
(e) Timely receipt of all recommended preventive care services
(f) Medication reconciliation with review of adherence and potential interactions
(g) Oversight of patient self-management of medications
vii. Patient center care plan document that includes the following:
(d) Congruent with patient choices and values
(e) Based on physical, mental, cognitive, psychosocial, functional, and environment (re)
assessment and an inventory of resources and supports
(f) Comprehensive for all health issues and typically includes the following elements:
(1) Problem list
(2) Expected outcome and prognosis
(3) Measurable treatment goals
(4) Symptom management
(5) Planned interventions
(6) Medication management
(7) Community/social services ordered and how they will be coordinated
(8) Individuals responsible for each intervention
(9) Requirements for periodic review and revision of the care problem

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-203
 Managing a Clinical Practice

viii. Management of all care transitions (e.g., other clinicians, emergency department, hospitals,
long-term care)
(d) The practice must facilitate communication of relevant patient information through
electronic exchange of a summary care record.
(e) The practice must have qualified personnel who are available to deliver transitional care
services in a timely way.
ix. Coordination, communication, and documentation of such with home and community-based
clinical service providers
d. EHR requirement – Alignment with meaningful use requirements
iv. Ability to fulfill the scope of service and other elements above
v. EHR certified to the edition of certification criteria that is acceptable for the EHR
Incentive Programs as of December 31 of the calendar year before the Physician Fee
Schedule (PFS payment year)
vi. Meet the final core EHR capabilities (structured recording of demographics, problems,
medications, medication allergies, and creation of a structure clinical summary record)
e. May be billed under HOPPS. Required to inform the patient that the hospital personnel are
providing this service
f. May be used by FQHCs and rural health clinics as of January 1, 2016. Recommend reviewing the
regulations because there are some leniencies in EHR requirements and nuances in billing with
FQHC rules. CMS guidance for FQHCs may be found at https://www.cms.gov/Outreach-and-
Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM9234.pdfg.
Has been difficult to operationalize. CMS put out a call letter requesting comment on operational
issues. Expect the rules for this service to change.

G. Community Pharmacy – Part D MTM Services

1. As a result of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003,
Medicare contracts with PDPs to provide MTM services.
2. PDPs then contract with pharmacists and/or pharmacies to provide these services or may provide
these services with internal staff.
3. May or may not use MTM codes
4. Requirements updated yearly in the CMS call letter, usually released in the spring before the year the
regulations are implemented. The following are the 2014 requirements for Medicare Part D MTM services:
a. Eligible beneficiaries to have an annual CMR (comprehensive medication review)
i. Interactive person-to-person visit
ii. Telehealth consultation
b. At least quarterly TMRs (targeted medication reviews) with follow-up interventions when necessary
c. Opt-out only. All eligible beneficiaries are to receive these services unless they decline to participate.
d. May be furnished by a pharmacist or other qualified provider
e. May distinguish between services in ambulatory and institutional settings
f. Must be developed in cooperation with licensed and practicing pharmacists and physicians
5. Eligibility for MTM services under Medicare Part D
a. Three chronic health conditions
b. Five of nine core chronic conditions
c. Eight Part D medications
d. Likely to incur Part D drug costs of $3017 or greater

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-204
 Managing a Clinical Practice

H. MTM CPT Codes

1. 99605 (previously 0115T): New patient, face-to-face visit: Initial 15 minutes
2. 99606 (previously 0116T): Established patient, face-to-face visit: Initial 15 minutes
3. 99607 (previously 0117T): Face-to-face visit
a. For each additional 15 minutes
b. Used only in addition to 99605 or 99606
c. List separately.
4. Summary of current use
a. Lack of universal reimbursement for codes
b. Used in some state Medicaid programs and some prescription drug benefit programs
c. Potential to use in private contract reimbursement

I. Private Payers
1. Contractual relationships in which all aspects of the service are negotiated between the
pharmacist and the payer
2. Can be done with the following:
a. Commercial payers
b. Self-insured employers
c. Health care organizations

J. State-Based Programs
1. California
2. Florida
3. Iowa
4. Minnesota
5. Montana
6. New Mexico
7. North Carolina
8. Ohio
9. Wisconsin
10. Others?

K. Self-Paying Patients: Depends on fees for service and ability to pay by your customers

L. New Models of Payment for New Models of Care

1. Enhanced fee for service
a. Fee for service plus care management fee plus pay for performance
b. Pros: Easy to administer
c. Cons
i. Volume of care remains a driver.
ii. Incentive to provide unnecessary care
iii. Does not reward comprehensive care or sustainability of the new models of care
2. Risk-Adjusted Comprehensive Payment and Bonus Model or a capitated payment model with quality bonus
a. Pros
i. Removes volume as payment driver
ii. Rewards outcomes
iii. Easy to administer

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-205
 Managing a Clinical Practice

b. Cons
i. Potential to avoid outliers at the expense of efficiency
ii. Risk may be high if it is full risk or risk sharing agreement, which means that the provider
must absorb any financial losses or share at some percentage any financial losses that occur.
This completely transfers the responsibility of knowing and managing costs and expenses at
a continual and granular level squarely on the provider.
3. Prometheus Evidence-Informed Case Rate model
a. Case rate for conditions based on local peer episodes of care aligned with evidence-based
medicine and incentives toward improvement
b. Fee for service for acute and preventive services
c. Pro – Payment aligned with best practices
d. Con – Complex to administer

Practice Case 4

Your site is pleased with the services you are providing. Administration is interested in investigating billing
for your services. You present to administration and the medical staff the options for pharmacist billing in the
physician-based office setting. These include incident-to physician billing at the 99211 CPT code, transition-of-
care participation and billing, chronic care billing, and billing pharmacist-conducted follow-up wellness visits.
The compliance officer is not comfortable with the 99211 billing of your services because they are titled MTM,
which is not a covered benefit under Part B Medicare. In addition, the reimbursement rate may not be worth
the effort. Currently, the office is struggling with physician schedules for hospital-discharged patients to be
seen in the 7-day higher-reimbursed time. A proposal is developed to use pharmacy services to complete most
coordination and transition work within 72 hours post-discharge, either by telephone or within 30 minutes before
the physician visit. Reducing time spent by the physician for discharge visits would create the needed physician
visit slots within the 7-day period. Removing follow-up wellness visits would also create more visit slots in
physician schedules. A plan is created to expand pharmacy services for transition-of-care and wellness visits.

During the past several years, several new opportunities well aligned with pharmacist services have become
available to provide revenue generation to help support pharmacist patient care programs.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-206
 Managing a Clinical Practice

VII. SUSTAINING YOUR PRACTICE FOR THE FUTURE

A. Planning for Growth

1. Using structure-related measures (remember the balanced scorecard), monitor the growth of your
service at least quarterly.
a. Number of referrals
b. Number of patients in your clinic
c. Number of visits
d. Complexity of patients
e. Swing patterns of the above measures
f. Non–patient care workload
i. Quality assurance or pay-for-performance measurement
ii. Research activities
iii. Administrative tasks
(a) Committee work and meetings
(b) Teaching
2. At 90% capacity, have a plan for hiring additional staff.
a. Know the timeline for hiring in your organization.
b. Know the timeline and availability of qualified pharmacists and other staff in your community.
3. Managing growth
a. Short-term solutions
i. Review processes and shift any work that you can to ancillary staff. May be easier to add
ancillary staff, if needed, to your team
ii. Close your service to new referrals, or refer the patient back to the referring provider for
continued management until you can secure the needed staffing for growth (least desirable).
iii. Redistribute responsibilities in the non–patient care duties for the short term.
b. Long-term solutions
i. Consider cross-training other pharmacists in your organization to assist in coverage during
high-volume periods.
ii. Hire additional practitioners.

B. Strategic Planning. A management activity used to set priorities and direction for your clinic or
organization so that you are adapting constantly to the environment and any changes foreseen
1. Review your current situation and your business plan. Is this the direction you are going?
Is it the direction you want to go? Change what has to be changed.
a. Mission and vision
b. Environmental scan
c. SWOT (strengths, weaknesses, opportunities, threats) analysis
d. Quality program and balanced scorecard
e. Identify what is needed to achieve excellence in your practice.
f. Reset goals and objectives to achieve the desired level of practice.
2. Setting the time interval. Many strategic plans use a timeline such as 5–10 years. Practice and health
care is a rapidly changing environment, so the strategic planning document may be ongoing and
visited regularly.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-207
 Managing a Clinical Practice

REFERENCES
1. ACCP Public and Professional Relations Commit- 10. Buffington DE, Bennett M. Medication Therapy Man-
tee. Should organized clinical pharmacy promote a agement Services: Documenting Pharmacy-Based Pa-
consistent process of patient care provided by clini- tient Care Services. Module 5. 2007. American Phar-
cal pharmacists that can apply to any clinical prac- macists Association. Available at www.pharmacist.
tice setting: part IIIB: application of major practice com/sites/default/files/files/mtm_documentating_pc_
models to sample cases. ACCP Rep 2012;31:2-18. services.pdf. Accessed December 15, 2013.
2. Agency for Healthcare Research and Quality (AHRQ). 11. Burke JM, Miller WA, Spencer AP, et al. ACCP white
2012 National Healthcare Quality Report. AHRQ Pub- paper: clinical pharmacist competencies. Pharmaco-
lication No. 13-0002. Rockville, MD: U.S. Department therapy 2008;28:806-15.
of Health and Human Services, May 2013. Available at 12. Center for Pharmacy Practice Accreditation (CPPA).
www.ahrq.gov/workingforquality/nqs/nqs2012annlrp- Available at http://pharmacypracticeaccredit.org/our-
tapa.htm. Accessed February 14, 2014. program/standards. Accessed September 15, 2014.
3. American Pharmacists Association and National 13. Centers for Medicare & Medicaid Services (CMS). 1995
Association of Chain Drug Stores Foundation. Med- Documentation Guidelines for Evaluation and Manage-
ication Therapy Management in Pharmacy Practice: ment Services. Available at www.cms.gov/Outreach-
Core Elements of an MTM Service Model. Version and-Education/Medicare-Learning-Network-MLN/
2.0. 2008. Available at www.pharmacist.com/sites/ MLNEdWebGuide/Downloads/95Docguidelines.pdf.
default/files/files/core_elements_of_an_mtm_prac- Accessed January 15, 2014.
tice.pdf. Accessed February 5, 2016.
14. Centers for Medicare & Medicaid Services (CMS). 1997
4. American Society of Health-System Pharmacists Documentation Guidelines for Evaluation and Manage-
(ASHP). ASHP Guidelines on Documenting Pharma- ment Services. Available at www.cms.gov/Outreach-
ceutical Care in Patient Medical Records. Best Prac- and-Education/Medicare-Learning-Network-MLN/
tices for Hospital and Health System Pharmacy. Posi- MLNEdWebGuide/Downloads/97Docguidelines.pdf.
tion and Guidance Documents of ASHP, 2005-2006 Accessed January 15, 2014.
ed. Bethesda, MD: ASHP, 2005:261-3. Available at
15. Centers for Medicare & Medicaid Services (CMS).
www.ashp.org/DocLibrary/BestPractices/OrgGdl-
Available at www.cms.gov/Medicare/Quality-Initia-
DocPMR.aspx. Accessed December 15, 2012.
tives-Patient-Assement-Instruments/PQRS/index.
5. ASHP guideline: minimum standard for pharma- html?redirect+/PQRS/. Accessed February 18, 2014.
ceutical services in ambulatory care. American So-
16. Centers for Medicare & Medicaid Services (CMS).
ciety of Health-System Pharmacists. Am J Health
Frequently Asked Questions About Billing Medicare
Syst Pharm 1999;56:1744-53.
for Transitional Care Management Services. Avail-
6. Barr MS. The patient-centered medical home: align- able at www.cms.gov/Medicare/Medicare-Fee-for-
ing payment to accelerate construction. Med Care Service-Payment/PhysicianFeeSched/Downloads/
Res Rev 2010;67:492-9. FAQ-TCMS.pdf. Accessed January 15, 2014.
7. Blair MM, Carmichael J, Young E, et al. Pharma- 17. Centers for Medicare & Medicaid Services (CMS).
cist privileging in a health system: report of the Medicare Shared Savings Program Quality Measure
Qualified Provider Model Ad Hoc Committee. Am J Benchmarks for the 2014 and 2015 Reporting Years.
Health Syst Pharm 2007;64:2373-81. Available at https://www.cms.gov/Medicare/Medi-
8. Brock KA, Casper KA, Green TR, et al. Documen- care-Fee-for-Service-Payment/sharedsavingspro-
tation of patient care services in a community phar- gram/Quality-Measures-Standards.html. Accessed
macy setting. J Am Pharm Assoc 2006;46:378-4. February 8, 2016.
9. Brown D, Ferrill MJ. The taxonomy of professional-
ism: reframing the pursuit of academic professional
development. Am J Pharm Educ 2009;73:1-10.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-208
 Managing a Clinical Practice

18. Centers for Medicare & Medicaid Services (CMS). 27. Donabedian A. The quality of care: how can it be as-
Providing the Annual Wellness Visit (AWV). Avail- sessed? JAMA 1988;260:1743-8.
able at www.cms.gov/Outreach-and-Education/Medi- 28. Galt KA. Credentialing and privileging for pharma-
care-Learning-Network-MLN/MLNProducts/Down- cists. Am J Health Syst Pharm 2004;61:661-70.
loads/AnnualWellnessVisit-ICN907786.pdf. Accessed
29. Glasgow J. Introduction to Lean and Six Sigma Ap-
January 15, 2014.
proaches to Quality Improvement. Expert Commen-
19. Centers for Medicare & Medicaid Services (CMS). Phy- tary. National Quality Measures Clearinghouse. May
sician Fee Schedule Look Up. Available at https://www. 16, 2011. Available at www.qualitymeasures.ahrq.gov/
cms.gov/apps/physician-fee-schedule/overview.aspx. expert/expert-commentary.aspx?id=32943. Accessed
20. Centers for Medicare & Medicaid Services (CMS). January 15, 2014.
Medicare Program; Revisions to Payment Policies Un- 30. Institute of Medicine. Medicare: A Strategy for Qual-
der the Physician Fee Schedule and Other Revisions ity Assurance. Washington, DC: National Academy
to Part B for CY 2016; Final Rule. Available at https:// Press, 1990.
www.gpo.gov/fdsys/pkg/FR-2015-11-16/pdf/2015-
31. IOM (Institute of Medicine). 2015. Vital Signs: Core
28005.pdf. Accessed January 30, 2016.
Metrics for Health and Health Care Progress. Wash-
21. Claxton KL, Woital P. Design and implementation ington, DC: The National Academies Press.
of a credentialing and privileging model for ambu-
32. Joint Commission of Pharmacy Practitioners. Phar-
latory care pharmacists. Am J Health Syst Pharm
macists Patient Care Process. May 2014. Available at
2006;63:1627-32.
www.pharmacist.com/sites/default/files/JCPP_Phar-
22. Council on Credentialing in Pharmacy. Credential- macists_Patient_Care_Process.pdf. Accessed Septem-
ing and privileging of pharmacists: a resource paper ber 15, 2014.
from the Council on Credentialing in Pharmacy. Am J
33. Juba KM. Pharmacist credentialing in pain manage-
Health Syst Pharm 2014;71:e109-18.
ment and palliative care. J Pharm Pract 2012;25:517-20.
23. Council on Credentialing in Pharmacy. Scope of Con-
34. Kaplan RS, Norton DP. Balanced Scorecard: Translat-
temporary Pharmacy Practice: Roles, Responsibilities
ing Strategy into Action. Boston: Harvard Business
and Functions of Pharmacists and Pharmacy Techni-
School Press, 1996.
cians. Washington, DC: Council on Credentialing in
Pharmacy, 2009. 35. Kleinman LC, Dougherty D. Assessing quality im-
provement in health care: theory for practice. Pediat-
24. Department of Health and Human Services, Cen-
rics 2013;131:S110.
ters for Medicare & Medicaid Services. Evaluation
and Management Services Guide. December 2010/ 36. Kliethermes MA. Outcomes evaluation: striving for
ICN: 006764. Available at www.cms.gov/Outreach- excellence in ambulatory care pharmacy practice. Am
and-Education/Medicare-Learning-Network-MLN/ J Health Syst Pharm 2014;71:1375-86.
MLNProducts/downloads/eval_mgmt_serv_guide- 37. Kliethermes MA, Brown TR, eds. Building a Suc-
ICN006764.pdf. Accessed December 15, 2012. cessful Ambulatory Care Practice: A Complete Guide
25. Department of Health and Human Services, Centers for Pharmacists. Bethesda, MD: American Society of
for Medicare & Medicaid Services. Medicare and Health-System Pharmacists, 2012.
Medicaid Programs: Hospital Outpatient Prospective 38. Kuo GM, Buckley TE, Fitzsimmons DS, et al. Collab-
Payment and Ambulatory Surgical Center Payment orative drug therapeutic management services and re-
Systems and Quality Reporting Programs; Hospital imbursement in a family medicine clinic. Am J Health
Value-Based Purchasing Organizations; Organ Pro- Syst Pharm 2004;61:343-54.
curement Organizations; Quality Improvement Orga- 39. Medicare Benefit Policy Manual. Chapter 15. Covered
nizations; Electronic Health Records (EHR) Incentive Medical and Other Health Services. Available at https://
Program; Provider Reimbursement Determinations www.cms.gov/Regulations-and-Guidance/Guidance/
and Appeals. Federal Register. 2013;78:74826-75200. Manuals/downloads/bp102c15.pdf. Accessed January
26. Department of Health and Human Services. Pri- 15, 2014.
mary care and care coordination. Fed Regist
2012;77:68978-94.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-209
 Managing a Clinical Practice

40. National Committee for Quality Assurance (NCQA). 50. Touchette DR, Stubbings J, Schumock G. Improving
The State of Health Care Quality: 2004. Washington, Medication Safety in High Risk Medicare Beneficia-
DC: NCQA, 2004. ries Toolkit. Effective Healthcare Research Report No.
41. O’Daniel M, Rosenstein AH. Professional communica- 38. (Prepared by the Duke University DEcIDE Center
tion and team collaboration. In: Hughes RG, ed. Patient under Contract No. 290-05-0032; the RTI International
Safety and Quality: An Evidence-Based Handbook DEcIDE Center under Contract No. 290-05-0036; and
for Nurses. Publication No. 08-0043. Rockville, MD: the University of Illinois at Chicago (UIC)/Chicago-Ar-
Agency for Healthcare Research and Quality, 2008. ea DEcIDE Center, under Contract No. 290-05-0038.)
Available at www.ncbi.nlm.nih.gov/books/NBK2637/. AHRQ Publication No. 12-EHC027-EF. Rockville,
MD: Agency for Healthcare Research and Quality, July
42.
Patient-Centered Primary Care Collaborative
2012. Available at www.effectivehealthcare.ahrq.gov/
(PCPCC). Guidelines for the Practice and Documenta-
reports/final.cfm. Accessed December 15, 2013.
tion of Comprehensive Medication Management in the
Patient-Centered Medical Home. Appendix A. Avail- 51. UDS Uniform Data System HRSA Calendar Year
able at www.pcpcc.org/sites/default/files/resources/ 2015. Available at www.bphc.hrsa.gov/datareporting/
Appendix_A_Guidelines_for_the_Practice_and_ reporting/index.html. Accessed September 29, 2015.
Documentation.pdf. Accessed December 15, 2013. 52. U.S. Burdens of Disease Collaborators. The state of US
43. Patient-Centered Primary Care Collaborative (PCPCC). health: 1990–2010: burden of disease, injuries and risk
The Patient-Centered Medical Home: Integrating Com- factors. JAMA 2013;310:591-608.
prehensive Medication Management to Optimize Pa- 53. U.S. Public Health Service. Indian Health Service:
tient Outcomes Resource Guide, 2nd ed. June 2012. Pharmacy Brand. Standards of Practice. Available at
Available at www.pcpcc.org/sites/default/files/media/ Accessed December 31, 2013.
medmanagement.pdf. Accessed December XX, 2013. 54. Varkey P, Reller MK, Resar RK. Basics of qual-
44. Pharmacy E-Health Information Technology Coopera- ity improvement in health care. Mayo Clin Proc
tive. The Roadmap for Pharmacy Health Information 2007;82:735-9.
Technology Integration in the US HealthCare. Avail- 55. Warshany K, Sherrill CH, Cavanaugh J, et al. Medi-
able at www.pharmacyhit.org/pdfs/11-392_RoadMap- care annual wellness visits conducted by a pharmacist
Final_singlepages.pdf. Accessed September 15, 2014. in an internal medicine clinic. Am J Health Syst Pharm
45. Robert Wood Foundation. Payment Matters: The ROI 2014;71:44-9.
for Payment Reform. February 2013. Available at www. 56. Woolf SH, Aron L, eds. U.S. Health in International
rwjf.org/content/dam/farm/reports/issue_briefs/2013/ Perspective: Shorter Lives, Poorer Health. Panel on
rwjf404563. Accessed January 15, 2014. Understanding Cross-National Health Differences
46. Rollinson R, Young E. Strategic Planning for the 21st Among High-Income Countries. Washington, DC:
Century: A Practical Strategic Management Process. The National Academies Press, 2013.
Chicago: LookingGlass Publishing, 2010. 57. World Health Organization (WHO). The World Health
47. Sachdev G. Sustainable business models: systemic ap- Report 2000: Health Systems Improving Performance.
proach toward successful ambulatory care pharmacy Geneva: WHO, 2000. Available at http://who.int/
practice. Am J Health Syst Pharm 2014;71:1366-74. whr/2000/en/whr00_en.pdf. Accessed December 15,
48. Snella KA, Trewyn RR, Hansen LB, et al. Pharma- 2013.
cist compensation for cognitive services: focus on the 58. Zieler-Brown (Haines) SL, Brown TR, Chen D, et al.
physician office and community pharmacy. Pharmaco- Clinical documentation for patient care: models, con-
therapy 2004;24:372-8. cepts and liability considerations for pharmacists. Am
49. The State of Value-Based Reimbursement and the J Health Syst Pharm 2007;64:1851-8.
Transition from Volume to Value in 2014. McKesson
Health Solutions 2014. Available at http://mhsinfo.
mckesson.com/rs/mckessonhealthsolutions/images/
MHS-2014-Signature-Research-White-Paper.pdf. Ac-
cessed August 13, 2015.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-210
 Managing a Clinical Practice

ANSWERS AND EXPLANATIONS TO SELF-ASSESSMENT QUESTIONS

1. Answer: B 4. Answer: D
It is important to remain current with the critical pro- Each of the answers describes an excellent measure ad-
cesses of a pharmacy service. Health care today is in a dressing desired outcomes of the Triple Aim set by CMS
state of rapid change, both clinically and operationally. to improve health care. Answer D is the optimal measure
Reviewing key documents annually will keep your prac- for population health as well as the focus of national pri-
tice up-to-date and current. Answer B. An annual review ority patient outcomes related to safety. Answer A is a
is also efficient, keeping the review process manageable measure that would show decreased cost through elimi-
and less disruptive to other pressing work you may need nation of inappropriate medications. Answer B and An-
to accomplish. Six months is probably too short a time swer C reflect the first aim of improved individual care.
frame for efficiency and 3 to 5 years is too long in this
current state of rapid health care change. 5. Answer: D
With medication measures composing 50% of the scor-
2. Answer: A ing system in the Medicare Five-Star Ratings Program,
Data are an extremely important tool in health care to- these measures are very important to Medicare Part C
day. Management of patients, populations, and quality plans. Answer D. The higher the rating achieved by the
measures is critical to sustainability. Therefore, your plan, the greater the payment received for managing the
documentation processes should allow efficient tracking beneficiaries in the plan. If a five-star rating is achieved,
of the elements you need in your clinic and organiza- the plan is awarded the ability to recruit patients to the
tion. Answer A. Usually, patient portals are a subset of plan for the entire calendar year. Consequently, if your
information in a separate patient and caregiver portal. work as a provider can influence the results, this will
Although payers will audit to ensure the documentation speak favorably for your service and organization in con-
justifies payments, this is not the most important purpose tracting with the plans. The CMS star ratings are an op-
of documentation from a clinician’s perspective. Using portunity for pharmacists to demonstrate value and im-
SNOMED codes in a system would be forward thinking; portance to organizations and payers. The other measure
however, the SNOMED coding system is still in develop- sets are important, but they may have greater attribution
ment and is not yet universally used or available. It may to the health care team, where the medication-related star
become the most important feature in the future. measures are a focus of MTM services and the contribu-
tion of pharmacists.
3. Answer: A
The PCPCC document was created from multidisci- 6. Answer: A
plinary input, with a focus on what other disciplines Privileging is the process that authorizes a provider to
desire to see in a pharmacist’s note. Per the PCPCC practice a set of services within an organization. Cor-
understanding indication, efficacy, safety and adher- rect answer is A. Privileging uses methods at the site,
ence are important documentation from a medication such as peer reviews of patient visits to ensure compe-
review. Answer A. The most important aspect to note tency. Credentialing is used to verify that the provider
is that its framework differs from other frameworks has the license and training to perform the services.
noted in the pharmacy literature. The framework listed Answer D testing, does not always translate into com-
in Answer C is the PCNE-DRP (Pharmaceutical Care petency in areas such as communication, writing, and
Network Europe–Drug-Related Problems) classification, other needed skills. Collaborative practice agreements
which has the strongest validity testing, and Answer D may or may not address proof of skill sets required to
is the framework proposed by Hepler and Strand (DICP perform a certain service.
1990;24:1093-7). Answer B is considered for verbal com-
munication of drug-related problems.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-211
 Managing a Clinical Practice

7. Answer: B
The Hospital Outpatient Prospective Payment System
consists of the regulations that govern only a hospital-
owned outpatient clinic that resides on the hospital phys-
ical campus. Answer B. Services may be identical to
services in other ambulatory sites. However, the billing
is done under the hospital as the Medicare provider, so it
falls under the HOPPS regulations. The remainder of the
answers are not hospital based clinics.

8. Answer: D
The supervision provision from incident-to billing in a
physician office or clinic requires that the physician or
the Medicare-recognized Part B provider be within the
office suite. Therefore, the physicians in other offices or
in the hospital are not eligible under supervision rules. A
nurse practitioner is a Medicare-recognized Part B pro-
vider and therefore may supervise your services as long
as that provider is in the office suite during your service
hours. Correct answer is D. Above the floor, across the
hall and across the street are unacceptable for incident
to billing under Medicare Part B. In the hospital clinic
setting, however, the supervising provider may be in the
building or in a connected building, but not across the
street. This is to ensure that the supervising provider can
be readily available, if needed. The endocrinologist in
the floor above yours is not eligible because, in this set-
ting, the supervising provider must be in the same suite.

9. Answer: D
The MTM codes are time based only and are unlike
other 99XXX E/M codes, which include medical com-
plexity assessments. Correct answer is D. There are no
RVUs associated with the MTM codes to adjust payment
with varying costs around the country. Currently, there
are no payments associated with the MTM codes in the
Medicare system.

ACCP Updates in Therapeutics® 2016: Ambulatory Care Pharmacy Preparatory Review and Recertification Course

1-212