1978 – Centers for Medicare and Medicaid Services (CMS) Requirements for quarterly Medication Regimen Reviews in Long Term Care
1987 – CMS Requirement for monthly Medication Review in Long Term Care
1990 – CMS Requirement for all patients to have Drug Utilization Reviews with dispensing at Pharmacy (LTC)
2003 – CMS “Conditions of Participation” highlights Nursing Facility must “record, store, administer and monitor medications” with mandate to:
- Reduce med errors, adverse drug events
- Assure proper medication selection
- Monitor interactions, over medication and under medication
- Improve documentation
2011 – CMS defines recommendation for consultant pharmacists to be independent from LTC pharmacy due to “conflict of ‘interest'” highlighted by multiple cases against some Pharmacies for improper “kickback” benefits and an “epidemic” of poor prescribing and distribution practices
2012 – Under heavy pressure from LTC Pharmacy Lobbyists and “impending” deployment of Affordable Care Act, CMS does not REQUIRE Consultant Pharmacy independence, but RECOMMENDS nursing facilities hire their own independent consultant pharmacists
2012 – CMS mandates Medication Regimen Reviews for patient stays under 30 days and/or changes in condition
2013 – CMS indicates that Medication Therapy Management services be made available to all patients including LTC patients within Part D requirements
2014 – CMS requires Medication Therapy Management services be offered by all Part D providers on an “Opt Out” basis, including LTC patients