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
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.