NACDS has taken the fight for pharmacy patient care to an intriguing and potentially highly consequential arena. A federal agency will decide whether pharmacies should be included in the definition of “value-based enterprise (VBE) participant,” and NACDS’ comments answer that question with a powerfully substantiated “yes.”

In a proposed rule, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) invited feedback as to whether pharmacies should be excluded from the definition of “VBE participant.” The decision is being made on one specific point of regulatory policy that relates to the Anti-Kickback Statute, and its “safe harbors” that apply to those providers instrumental in the coordination of care, rather than to those that primarily provide items. Exclusion from the definition would create yet another needless barrier to pharmacy patient care.

“Community pharmacies can and do play a critical role in coordinating and managing care for patients. As evidenced throughout our comments, community pharmacies should be included in the definition of ‘VBE participant.’ We urge OIG to remedy this misconception in the final rule,” wrote NACDS President & CEO Steven C. Anderson, IOM, CAE, in the comments.

“As you work through the HHS ‘Regulatory Sprint to Care’ to improve patient outcomes, produce health system efficiencies, lower costs, and transform our nation’s healthcare system to better pay for value, we urge you to consider how community pharmacies are helping to accelerate your efforts. Moreover, we urge you to consider how community pharmacies could further accelerate your efforts through recognition in the proposed rule,” he stated.

NACDS’ comments lay out a highly comprehensive case, with extensive citations of research that validate the economic value of community pharmacy patient care. NACDS’ comments also describe specific examples in which payors have recognized the value of pharmacy to improve quality and value, and incentivized pharmacies to deliver clinical care outside of dispensing prescriptions.

NACDS’ advocacy on this issue is part of its proactive campaign to enhance patients’ access to health and wellness services.