Medicare Releases Individual Prescriber Data

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On May 1, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released Medicare Part D prescription drug data that individual physicians, nurse practitioners, physician assistants, and other health care providers prescribed in 2013. This release of data follows various releases aimed at creating more transparency within the health care. For example, the Sunshine Act released payment information between drug and medical device manufacturers to physicians and teaching hospitals. Further, CMS released payment data to physicians and other health care providers on April 9, 2014. Although this data is a push for more transparency, it could represent a significant risk to health care providers.

The data released, contains individual data for each prescriber and drug.  This amounts to more than one (1) million individual health care providers who prescribed approximately $103 billion in prescription drugs under the Part D program in 2013. CMS provided the following chart highlighting the higher number of prescribers by specialty:


Average Costs and Number of Unique Drug Products for Specialties with the Highest Number of Prescribers, 2013

Specialty
Number of Prescribers
Average Total Costs
Cost per Claim
Average Number of Unique Drug Products Prescribed
Internal Medicine
130,640
$205,923
$63
65.7
Dentist
124,322
$855
$14
2.1
Family Practice
105,413
$211,977
$56
74.9
Nurse Practitioner
97,722
$67,708
$78
24.2
Physician Assistant
69,180
$47,405
$70
18.7
Emergency Medicine
43,664
$16,822
$41
9.5
Organized Health Care Education/Training Program - Student
42,307
$8,036
$67
5.6
Obstetrics/Gynecology
35,979
$15,953
$85
6.2
Psychiatry
25,906
$174,274
$104
28.3
Optometry
25,654
$17,501
$99
4.8


It should be cautioned that such data is not indicative of a specific providers prescribing patterns; however Medicare Part D equals billions per year in government reimbursements. Further, for providers or organizations that see a high proportion of Medicare patients, this data may be used in ways that could increase risk to your organization. This includes risks related to prescribing practices, forms of prescription fraud, or even technical non-compliance with prescribing documentation issues.

It is advised that providers and organizations should analyze this data carefully to ensure that any risks associated with this data being published are properly analyzed from both an operational and legal perspective.

If you have any questions or concerns related to the Medicare Part D program, or this recent release of data, please feel free to contact Robert A. Wade at (574) 485-2002 or Alex T. Krouse at (574) 485-2003.