Courtesy of ASCP
CMS has formally acknowledged and encouraged the involvement of clinical pharmacists in medication management and deprescribing activities through team-based care models. In newly released billing guidance tied to Deprescribing Services Codes, CMS confirmed that pharmacists can contribute billable time through “incident-to” services provided under physician or non-physician practitioner collaborations. The announcement arrives as Secretary Kennedy undertakes efforts aimed at reducing unnecessary prescribing. For pharmacists already embedded in collaborative care models, this development represents more than billing clarification and signals a growing recognition of the pharmacist’s expanding clinical role in optimizing medication therapy. However, CMS has historically limited the codes pharmacists can bill incident-to physicians and non-physician practitioners, prohibiting service delivery for many patients. As such, AAPP has been collaborating with APhA and ASHP to fix the larger issue to allow pharmacists to submit codes through incident to mechanisms that reflect the complexity of care pharmacists are providing. More recently, we requested an audience with CMS to discuss this latest development in billing opportunities for pharmacists.
In the FAQ Guidance, CMS specifically addressed whether pharmacist's time can count toward deprescribing services:
Yes, pharmacists can provide services incident to the professional services of a physician or non-physician practitioner just as other clinical staff may do (see the CY 2021 PFS final rule at 85 FR 84592 through 94593). These “incident to” services can count as billable time for reporting various care management services to the PFS under the appropriate level of supervision and other applicable “incident to” rules, and consistent with the care management service definitions. Pharmacists must be working within their scope of practice and in accordance with applicable state law, and the services cannot also be covered under Medicare Part D or paid under other Part B services. CMS encourages team-based care models that leverage the expertise of clinical pharmacists in medication management and deprescribing.” Pharmacists may be reimbursed for their clinical services under “incident to” billing for CPT codes: 99439, 99487, 99489, 99490, 99426 or 99427.