Impact of Final Short-Fill Rule on Medicare Part D Costs and Long-Term Care Pharmacy Dispensing

Abstract

To evaluate the impact of the final Centers for Medicare & Medicaid Services' (CMS) "short-fill" rule regarding the appropriate dispensing of prescription drugs in long-term care facilities. A prospective study to determine rates of unconsumed medication and the net-cost impact on Medicare Part D prescription drug plans based on the proposed and final CMS rule and other scenarios under consideration by CMS. Four hundred twenty-five long-term care facilities in six states. Residents covered by Medicare Part D. Rates of unconsumed medication, average dispensing fees, potential reduction in unconsumed medication, incremental fills, incremental dispensing fees, net cost or savings to Medicare Part D plans, and percentage increase in fills. Total estimates of the cost of unconsumed medication charged to Medicare Part D plans for residents in long-term care facilities are $87 million for brand products and $39 million for generics annually. Based on current dispensing fees, it is likely that implementation of the final rule will result in incremental costs to CMS plans in the range of $30 million annually. The number of Medicare Part D prescription fills will increase by about 20%. A seven-day fill requirement on brand products would raise incremental costs to more than $150 million annually, and inclusion of generic products in a seven-day fill requirement would result in incremental costs in the range of $850 million annually. The final CMS rule on short-fills is unlikely to result in savings to Medicare Part D plans. Shorter fill times and inclusion of generic products would significantly raise costs to these plans.