Life Science Compliance Update

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June 29, 2012

CME Coalitions Comments to CMS on Long Term Care and Consultant Pharmacists CE

Longterm Care Pharmacy
Recently the CME Coalition submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed rule to require Long Term Care (LTC) Consultant Pharmacists, who review patients medication schedules, to be independent from the LTC Pharmacies that serve those facilities.  As the Department of Health and Human Services (HHS) looks to determine a comprehensive approach to improving the quality of patient care in LTC facilities, the Coalition urged the Department to recognize the potential to improve patient outcomes through an enhanced commitment to continuing medical education (CME).

Under current regulations, long term care (LTC) facilities must provide, either directly or under arrangements with others, for the provision of pharmaceutical services to meet the needs of each resident.  This requires LTC facilities to employ or obtain the services of a licensed pharmacist to provide consultation on all aspects of the provision of pharmacy services in the facility, including a drug regimen review at least once a month for each facility resident. 

Background on CME Coalition  

The CME Coalition represents a collection of CME provider companies, in addition to other supporters of CME and the vital role it plays in our health care system.  Member organizations manage and support the development of healthcare continuing education programs that impact more than 500,000 physicians, nurses and pharmacists annually. 

Independence of LTC Consultant Pharmacists  

The CME Coalition recognized that the over-prescription of psychotropic drugs and the use of chemical restraints in nursing homes presents direct health risks to patients in these settings, and believe there is an important role that CME can play in better educating health care providers as to the risks involved with these drugs.  Accordingly, the Coalition urged CMS to consider a role for CME as the agency finalizes rules in this area. As health care and educational professionals who value the importance of enhancing the continuing education of the country’s health care providers, the Coalition considers “it vital that the Department recognize the potential to improve patient outcomes through an enhanced commitment to CME.” 

To support its comments, the Coalition pointed to recent data, which suggests that health care providers who participate in additional educational programs are significantly more likely to provide appropriate diagnoses and prescriptions that those who do not attend such programs.   Specifically, a recent survey of physicians found that 94% said CME was very useful or somewhat useful to stay informed about medications to treat particular conditions.   With respect to the educational value of industry supported programs: 

  • 59% of attendees always or usually gain improved clinical knowledge
  • 63% of attendees always or usually learn about potential side effects of medicines
  • 54% of attendees always or usually gain knowledge of new uses for medicines
  • 58% of attendees always or usually improve knowledge of the range of treatment options
  • 54% of attendees always or usually add knowledge about emerging drug risks
  • 50% of attendees always or usually strengthen ability to care for patients 

The Coalition noted that today, “it would seem impossible for a consultant pharmacist to be competent in their review without the information, tools, data, and other resources provided through continuing education.”  In addition, they maintained that “greater educational requirements for physicians could be instrumental in reducing unnecessary prescriptions.”   The Coalition concluded its comments by recognizing how “CME serves an irreplaceable role in disseminating this information to health care professionals and should be a focus of the Department’s response to these concerns.”

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