Impact of Final Short-Fill Rule on Medicare Part D Costs and Long-Term Care Pharmacy Dispensing

Objective: To evaluate the impact of the final Centers for Medicare & Medicaid Services’ (CMS) “short-fill” rule regarding the appropriate dispensing of prescription drugs in long-term care facilities. Design: A prospective study to determine rates of unconsumed medication and the net-cost impact on Medicare Part D prescription drug plans based on the proposed and final CMS rule and other scenarios under consideration by CMS. Setting: Four hundred twenty-five long-term care facilities in six states. Patients: Residents covered by Medicare Part D. Main Outcome Measures: Rates of unconsumed medication, average dispensing fees, potential reduction in unconsumed medication, incremental fills, incremental dispensing fees, net cost or savings to Medicare Part D plans, and percentage increase in fills. Results: Total estimates of the cost of unconsumed medication charged to Medicare Part D plans for residents in long-term care facilities are $87 million for brand products and $39 million for generics annually. Based on current dispensing fees, it is likely that implementation of the final rule will result in incremental costs to CMS plans in the range of $30 million annually. The number of Medicare Part D prescription fills will increase by about 20%. A seven-day fill requirement on brand products would raise incremental costs to more than $150 million annually, and inclusion of generic products in a seven-day fill requirement would result in incremental costs in the range of $850 million annually. Conclusion: The final CMS rule on short-fills is unlikely to result in savings to Medicare Part D plans. Shorter fill times and inclusion of generic products would significantly raise costs to these plans.