"We acknowledge that there are instances where multiple prescribers and pharmacies are writing and dispensing medications to the same patient and unaware that the patient is receiving the same drug or similar drugs from other sources. The best way to address that information gap is for the plans to share the information with the other prescribers so that these prescribers can reconcile the patient’s multiple medications and ensure the beneficiary is getting appropriate care."
Madara wrote that CMS should "acknowledge that physicians are best equipped to evaluate the medication needs of their patients and CMS should not promote the adoption of policies that substitute physician clinical judgment with that of (Part D drug plan) sponsors."
CMS, however, said its policy change was in part in response to a report last September from the Government Accountability Office.
That report detailed "egregious overutilization of medications from Part D beneficiaries who were obtaining medications from a minimum of five different prescribers and a maximum of fifty prescribers, with the vast majority of beneficiaries receiving medications from between five and ten providers.
The medications most often identified as being potentially overprescribed were hydrocodone containing products (e.g., Vicodin and Lortab ) followed distantly by oxycodone containing products (e.g., Percocet and Oxycontin)."