What's Not Up, Doc? Community Pharmacy Accreditation
Two different efforts are underway to accredit community pharmacies. Although these would be voluntary accreditations (at least initially), NCPA continues to oppose community pharmacy accreditation because it's yet another "stick" to community pharmacists rather than a "carrot" that would give pharmacies an incentive to participate.
One effort is led by a health care accrediting organization called URAC. The other is a combined effort by the American Pharmacists Association (APhA) and the National Association of Boards of Pharmacy (NABP) called the Center for Pharmacy Practice Accreditation (CPPA).
Since 1998 NCPA's official position has been to support individual state boards of pharmacy as the regulating bodies for pharmacy, rather than another entity providing national oversight. While neither of these accrediting programs would be regulating bodies (at least initially), we are not hearing of demand from community pharmacies, patients, or payers to accredit pharmacies. Two years ago, NCPA surveyed its members about community pharmacy accreditation, and 77% of the respondents said national accreditation was not necessary. The concerns I listed in the Aug. 27, 2010 Executive Update were:
- Is there evidence that suggests accreditation is needed?
- If evidence exists, accreditation should be voluntary.
- More dialogue is needed with the affected stakeholders and each state board responsible for oversight of pharmacies and pharmacist licensure.
- If accreditation is needed, it should not create a profit center for any accrediting body.
Additional concerns are:
- The costs—the fee to the accrediting body plus the cost to prepare for accreditation
- How long will it take before "voluntary" becomes "required" accreditation?
- Will accreditation be used as the "admission ticket" for pharmacies to participate in restricted networks?
- Is this a precursor to a national board of pharmacy, eventually making the state boards less relevant?
- Would sampling be permitted as it was by most DME accrediting programs (i.e., a few years ago when pharmacies with less than 5% of the business were required to be accredited to sell DME, only a few of a chain's pharmacies had to be accredited while every independent pharmacy location had to be accredited)?
- Where are the incentives for community pharmacy?
On that last point, the conversation changes if accreditation is a carrot rather than a stick. For example, URAC's history with pharmacy has included accrediting PBMs, mail order pharmacies, and specialty pharmacies. If accreditation meant higher reimbursement that more than paid for the accreditation fees, it's a somewhat different conversation. If accreditation meant a different auditing process than the current model that has the PBM as prosecutor, judge, and jury, again it's a different discussion. Unfortunately, the concern is that accreditation has a greater likelihood as being used as an unfunded stick than as a carrot.
NCPA has talked in Executive Update about the importance of community pharmacies aggregating on numerous occasions. As pharmacies diversify their revenue streams, I could see a health plan hiring a network of community pharmacies to provide services such as adherence, blood pressure screenings, diabetes counseling, immunizations, or asthma and other pharmacist-delivered patient care services.
But does that health plan care that the pharmacy is accredited? Or instead, does it care that the pharmacy network will, for example, follow an agreed upon protocol with high blood pressure patients and document the outcome? My bet is that what the health plan cares about is results... not if the pharmacy is accredited.
Maybe, in the hypothetical scenario described above, the health plan would want participating pharmacists to take a continuing education course so they know that all the participants are on the same page with the protocol. There would be a carrot in that model, but that's a far cry from the more invasive, more costly, less specific community pharmacy accreditation models that are being designed.
APhA coordinated the drafting of the standards for the CPPA accreditation program. To its credit, despite knowing how controversial accreditation is, APhA has invited comments from NCPA members and all of community pharmacy.
If you want to provide feedback, go online and submit your comments by Aug. 15. URAC also recently released its draft standards and is looking for comments from the pharmacy community. The deadline for comments to URAC is Aug 17.
NCPA will be providing comments to both sets of draft standards, and we encourage you to do so as well. In addition, NCPA will be sending all members a separate communication in the coming days with instructions on how to submit comments to both sets of standards, as well as talking points for your consideration. Please send a copy of the comments you submit to either organization to Carolyn Ha, PharmD, NCPA director of professional affairs, at Carolyn.Ha@ncpanet.org.
While we certainly respect our pharmacist colleagues, we have told them that as currently structured, a significant majority of NCPA's membership disagrees with what they are drafting. Community pharmacy accreditation has all the makings of another stick at a time when community pharmacy needs more carrots.