Abstract

In April 16 comments on a CMS proposed rule on medical loss ratio (MLR) requirements for Medicare Advantage (MA) and Part D, APhA highlighted the agency’s recognition throughout its 2014 fi nal advance notice and call letter of the importance of medication therapy management (MTM). The proposed rule (http://apha. us/11hkrqU) requested feedback on whether MTM should be included in the calculation of MLR. On page 12438 of the proposed rule, CMS wrote: “We solicit comment on whether Medication Therapy Management requirements for the Part D program would be consid-

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