What is the timeline for implementation?

Beginning January 1, 2013, all pharmacies which are servicing long-term care (LTC) facilities, including mail order and retail pharmacies, will be required to adhere to this new regulation.

What is the maximum amount of days which brand drugs can be dispensed?

Brand drugs must be dispensed at 14-days-or-less.

• CMS will waive the reporting requirement for pharmacies that agree to apply 7-day-or-less dispensing (not the required 14-day-or-less) for both brand and generic drugs.

Can generics be dispensed in a different quantity?

Yes, however CMS is encouraging shorter cycle based upon needs to the LTC facility. Having different quantities dispensed of brand and generic can be a cause for confusion and frustration with nursing staff.

• CMS is allowing the LTC facilities to select the dispensing methodology to be used within each facility as long as it is "uniform" within that facility. This applies to all Part D sponsors and pharmacies dispensing to beneficiaries within that facility.
• CMS defines "uniform dispensing techniques" to include both the packaging system and dispensing increment (14-day, 7-day, etc) as the dispensing methodology.

Does this apply to liquids dispensed from the pharmacy?

No, this is applying only to the solid oral medications.

• CMS agrees to limit short-cycle dispensing to solid oral dosage forms only, excluding liquids. Antibiotics and drugs in original packaging are exempt. Controlled substances will not be exempt.

Is there costs savings to the nursing home which could be realized from shorter cycle dispensing?

Absolutely, the savings can vary dramatically depending upon how medications are packaged and dispensed by the pharmacy to the amount of waste that is generated by the Part A residents. Although costs will be reduced with managing waste, the impact on nursing staff and labor may be increased.

Does this rule apply to residents with Part D Plans?

Yes, it applies to all Part D sponsors as long as dispensing method technique is uniform within the facility. Further, Part D sponsors should NOT request credits for drugs that are dispensed but not consumed by the patient.

Are all unused medications required to be reported?

Yes, CMS is requiring that all unused drugs be reported by the plan sponsor.

• CMS will waive the reporting requirement for pharmacies that agree to apply 7-day-or-less dispensing (not the required 14-day-or-less) for both brand and generic drugs.
• CMS is requiring that all unused drugs be reported by the plan sponsor. CMS is not requiring all unused drugs to be returned to the pharmacy, as per the proposed rule.