Policy & Regulation News

Does Medicare Part D Prescriber Data Improve Transparency?

By Jacqueline DiChiara

- The Centers for Medicare & Medicaid Services (CMS) has announced the availability of updated privacy-protected data on Medicare Part D prescription drugs. The presented data explains which prescription drugs were prescribed to Medicare Part D beneficiaries by one million unique healthcare professionals and physicians in 2013.

Medicare Part D Prescriber Data

The release of new privacy-protected data is part of a broad industry-wide initiative following an announcement earlier this year from Sylvia M. Burwell, Secretary of The Department of Health and Human Services (HHS), regarding the establishment of specific goals for value-based payment and alternative payment models for the first time in the entire history of the Medicare program. The primary objectives of CMS' data initiative in light of Burwell's push away from fee-for-service include the open, secure sharing of data and timely, open-minded insight and innovation in the future delivery of healthcare.

CMS' newly available data includes the total drug cost paid by beneficiaries and Part D plans for each prescriber and drug. $103 billion in prescription drugs and supplies were paid under the Part D program for 3,000 distinct drug products, CMS confirms, emphasizing their increased transparency efforts to increase awareness and comprehension regarding Medicare Part D.

“This transparency will give patients, researchers, and providers access to information that will help shape the future of our nation’s health for the better,” says Acting CMS Administrator Andy Slavitt. “Beneficiaries’ personal information is not available; however, it’s important for consumers, their providers, researchers, and other stakeholders to know how many prescription drugs are prescribed and how much they cost the health care system, so that they can better understand how the Medicare Part D program delivers care.”

The ripple effects of this amplified understanding are not exactly fleeting droplets that will reverberate for a brief moment before quietly vanishing. They are washing over the healthcare indutry in the form of hearty tidal waves and monsoons. The reason is due to numbers. Sixty-eight percent of Medicare beneficiaries – a total of 36 million people – are enrolled in the Part D program, reports CMS. Such data will make the healthcare system more affordable and accountable, says CMS.

CMS has already announced additional efforts to promote quality care through wise spending with its introduction of the Hospital Consumer Assessment of Healthcare Providers and Systems Survey (HCAHPS), a quarterly hospital star-ratings system designed to heighten consumer and provider transparency.

Will the newly released data set increase transparency within the healthcare industry? To what extent might this occur? In relation to data associated with the alleged smaller ripple effects of HCAHPS' transparency, some experts and leaders within the healthcare industry confirm trepidation.

The American Medical Association notes data’s limitations

In response to the aforementioned news, healthcare leaders are speaking out, including Robert M. Wah, MD, President of the American Medical Association (AMA), who confirmed the AMA’s similar commitments and efforts to improve the healthcare industry with strengthened transparency and increased accessibility of the widely disseminated information.

Wah suggests the data be presented more systematically with especially necessary information emphasized visually. “The data released today is much more complex than initially meets the eye,” says Wah. “The limitations of it should be more comprehensively listed and highlighted more prominently so that patients can clearly understand them,” Wah confirms, perhaps referring to a series of Excel spreadsheets that may be interpreted as an aesthetical headache to sift through visually due to an abundance of data presented sans graphic variation.

Wah mentions two additional suggestions for CMS to consider regarding the data set. First, Wah explains the information presented currently is too superficial to be meaningful for the healthcare industry, especially physicians. Says Wah, “We are also troubled by the lack of context provided with the data that could help explain physician prescribing practices and pharmacy filling practices before conclusions are drawn.”

In addition to urging CMS to improve public transparency, Wah also advises CMS strive to provide physicians with accurate, timely, and actionable data. This type of data will fruitfully sustain implementation of innovative delivery and payment models and resultantly improve patient care, maintains Wah.

CMS confirms it is addressing limitations

CMS openly addresses some of the limitations Wah mentions, stating, “Of particular importance is the fact that the data may not be representative of a physician’s entire practice or all of Medicare as it only includes information on beneficiaries enrolled in the Medicare Part D prescription drug program (i.e., approximately two-thirds of all Medicare beneficiaries).” CMS adds there may be gaps in the data, as it is not intended to indicate care quality provided and only contains cost and utilization information.

Additionally, CMS confirms some of the data may be inaccurate as it was pulled from various sources and may require correction.

Regarding drug cost information, CMS confirms the total drug cost does not represent the amount Medicare paid for the prescription in the Part D Prescriber PUF. According to CMS, “Because the drug expenditures derived from the Prescription Drug Event data comprise only a piece of the payment process, it is not possible to directly attribute total drug costs at the prescriber or drug level to payments from the Medicare trust fund. Furthermore, these total drug costs do not reflect any manufacture rebates.” 

Perhaps CMS will soon incorporate more relevant information into its data that is currently missing, such as information about treatment quality, what types of patients required physician care, or which specific drugs were administered in physicians’ offices and subsequently billed to the Medicare Part B program. Keeping the healthcare industry keenly aware and vivaciously educated requires a tremendous deal of effort, communication, and candid visits back to the drawing board. Nonetheless, providers and payers are indeed yearning for actionable, clearly presented, accurate data that will help enact positive change within the industry at large -- glorious tidal waves and beyond.