The American Pharmacists Association (APhA), the nation’s largest and oldest professional
organization representing pharmacists providing care across all practice settings and the National
Alliance of State Pharmacy Associations (NASPA), representing all state pharmacy associations,
commend the Administration for highlighting high-quality, patient-centered health care as an
essential element for healthy aging.
The WHCOA’s Healthy Aging policy brief touches on the importance of preventive health
services, chronic condition management, and injury prevention to the well-being of older
Americans. In response to WHCOA’s first discussion question (“What do older adults and their
families need to manage their chronic conditions and to optimize their physical, cognitive, and
behavioral health?”), APhA and NASPA have several suggestions to enhance ongoing efforts to
improve services in these three essential areas:

Preventive Health Services (p. 2): We encourage the Administration to increase older
Americans’ access to preventive health services by allowing qualified and accessible
health care providers, like pharmacists, to provide these services in government programs
like Medicare. The shortage of primary care providers is expected to worsen, which will
only make the accessibility to non-urgent care like preventive services more difficult,
particularly for those who are already medically underserved. Pharmacists are among the
most accessible clinicians and can provide a wide range of services, including certain
preventive services such as health and wellness testing and immunization administration,
as well as chronic disease management and care coordination during care transitions.
Currently, with some limited exceptions, Medicare Part B does not allow beneficiaries to
receive these services from their pharmacist, a professional with whom they already have
a trusted relationship. This unnecessarily restricts patients who are in need of care from
access to valuable services that pharmacists can provide, and limits the opportunity to
increase beneficiary participation in services like Medicare's Annual Wellness Visit.
Given that more than 90% of Americans live within 5 miles of a community pharmacy,
fully utilizing pharmacists for vital services will improve access to quality care for older
Americans, increasing the likelihood that they will receive preventive care.

Chronic Condition Management (p. 3): Proper medication management plays a
significant role in health outcomes for patients with chronic conditions. As the
medication experts on the health care team, pharmacists are uniquely situated to ensure
that patients understand their medications and the importance of adherence to care
regimens. APhA supports efforts to improve patient self-management, but encourages
the Administration to supplement these self-management programs with the expansion
and enhancement of medication therapy management (MTM) programs for Medicare
patients. Currently, only about a quarter of Medicare beneficiaries are eligible for MTM
services in the Part D program and the actual utilization rates are far lower. Variation in
Part D plans’ MTM eligibility criteria creates confusion for providers and beneficiaries
alike and simpler, consistent criteria would create clear eligibility parameters that would
likely lead to more consistent utilization and, correspondingly, increased benefits to
beneficiaries. Likewise, because pharmacists are not recognized as Medicare providers,
many are precluded from participating in team-based care models where they could
contribute to managing chronic conditions and the medications associated with them.
Access to medication management services provides an opportunity for patients with
chronic conditions to sit down with medication experts who can assess all of their
medications (including for falls prevention), work with other health care providers to
address problems, answer questions, and better prepare them to manage their
medications. By providing patients with baseline knowledge, expanded and enhanced
medication management programs could further bolster the Administration’s efforts to
improve patient self-management.
Additionally, as the Administration considers options for improving chronic condition
management, we encourage a closer examination of barriers that can adversely impact
care coordination for patients with chronic conditions. As noted above, medication
management is an essential element of chronic care management--yet pharmacists, who
have more medication-related education and training than any other health care provider,
often face barriers to full participation in emerging integrated care delivery models.
Specifically, pharmacists lack full access to health information technology systems and
government programs limit patient access to the pharmacists for many health care
services. If these issues are remedied, pharmacists will be able to work with other health
care providers to provide patients more effective, efficient, and coordinated care. Such
integration will help prevent disease complications associated with asthma, chronic
obstructive pulmonary disease, diabetes, congestive heart failure, and other chronic
diseases, which lead to increased health care utilization and escalation of total health care
costs.

Preventing Injury (p. 3): APhA commends the Administration’s work on fall prevention
and encourages additional investment in research on older patients who take medication
that increases the risk of falls (e.g., antidepressants). Recent preliminary research results
indicate that when pharmacists intervene with patients on these drugs, risk of injury due
to a fall decreases. Considering the high toll of falls, we believe placing an additional
focus on researching the impact of pharmacists’ intervention is warranted. We also
recommend that successful falls prevention practices and programs be highlighted and
shared among health care professionals, and that incentives be developed to increase
uptake of these practices in the marketplace.
In response to WHCOA’s second discussion question (“How can we ensure that older adults
know about, and take advantage of, the preventive services available to them under Medicare?”),
while APhA and NASPA cannot comment extensively, we do suggest expanding provider
education programs regarding MTM programs and other services and allowing provider referrals
(including both physicians and pharmacists) for MTM services. We have heard from our
members that many patients are hesitant to take advantage of services that are not directly
offered to them by a known provider (e.g., services offered via phone calls). Thus, if services are
offered or suggested by a trusted provider, older adults may be more likely to utilize them.
APhA and NASPA thank the Administration for its efforts to promote healthy aging and for the
opportunity to provide our input. We look forward to continuing to work with the
Administration and other stakeholders to improve patient care quality and outcomes.