Week 1
Announcing Fast Facts Series: PSW Provider Status Implementation
Each week for the next 8 weeks, Fast Facts will include steps that pharmacists in ambulatory care and community practice settings can take to prepare for Medicaid’s recognition of pharmacists as providers. The previous week’s steps will be linked for easy access.
Step 1: Familiarize Yourself with Act 98
2021 Wisconsin Act 98 (i.e., Act 98) adds pharmacists to Wisconsin’s list of recognized healthcare providers whose services must be reimbursed by Wisconsin Medicaid. Act 98 does not affect Medicare. The federal government has jurisdiction over Medicare-covered entities, while the state government has partial jurisdiction over state-funded payers (Medicaid) and private insurers.
Check out the PSW Wisconsin Pharmacist Provider Status webpage and FAQ document to learn more about Act 98!
Want More This Week? Learn about Medical Billing!
To be a provider for Medicaid, pharmacists will need to understand at least the basics of medical billing. Watch this 1-hour Medical Billing 101: What You Need to Know to Bill as a Provider CE to learn about common AMA CPT codes, how to select the appropriate AMA CPT codes for patient care, and the steps to prepare to bill Wisconsin Medicaid for patient care services. Click here to register.
Week 2
Fast Facts Series: PSW Provider Status Implementation
Step 2: Apply for an NPI Number
The National Provider Identifier (NPI) number is a unique identification number for providers and is required for submitting medical claims. Find resources about the NPI number and how to apply for one on the Centers for Medicare and Medicaid Services webpage. A personal NPI number will be required to bill for medical services for Medicaid patients.
Want More This Week? Learn about Collaborative Practice Agreements!
Visit the PSW website and become familiar with Collaborative Practice Agreements (CPAs) in the PSW CPA toolkit. A physician must sign CPAs for Medicaid reimbursement of medical services outside the pharmacist's scope of practice. Wisconsin Statute 450.01(16) lists vaccine administration and non-vaccine injection administration as included in the scope of pharmacy practice. Additionally, pharmacists can provide services such as point-of-care testing for CLIA-waived tests without a CPA, as anyone covered by a CLIA waiver can perform CLIA-waived tests. Similarly, disease-specific patient education can be provided by a pharmacist, though not explicitly outlined under the "practice of pharmacy."
Wisconsin statutes define the "practice of medicine" as "To examine into the fact, condition or cause of human health or disease, or to treat, operate, prescribe or advise for the same, by any means or instrumentality." A CPA is needed for anything under the practice of medicine that isn't otherwise allowed under the "practice of pharmacy." Therefore, diagnoses with non-CLIA waived tests, ordering labs, treatment, and prescribing would require a CPA.
Week 3
Step 3. Familiarize Yourself with Privileging and Credentialing within your Organization
Credentialing is the process of obtaining, verifying, and assessing the qualifications of an individual practitioner to provide patient care services. Privileging is the process of granting a qualified provider authorization to provide care, treatment, and services. Credentialing and privileging processes may be implemented in all pharmacy practice settings where patient care is provided, including, but not limited to, ambulatory clinics, community-based pharmacies, hospitals, and long-term care facilities. Initial credentialing may also be termed "Enrollment" by payer organizations such as ForwardHealth.
Organizational Privileging
Privileging applications are used by organizations to assess competence, relevant experience, and credentials to justify clinical privileges. These applications are reviewed by credentialing and privileging committees or experts in privileging within the organization. Examples of privileges might include anticoagulation management, chronic disease state management, antimicrobial therapy management, or authorization to order specified medications and labs.
Organization-specific policies will determine which providers need to complete this process. However, it would be reasonable for organizations initiating or expanding clinical services beyond those required for entry-level pharmacy practice to consider creating a privileging process for pharmacist providers. Once privileged, pharmacists may need to reapply for privileges at a frequency defined by their institution. This may involve a peer review process to ensure continued clinical competence and adherence to practice standards. To read more about Pharmacist Credentialing, please access this link.
References
- Council on Credentialing in Pharmacy. Guiding Principles for Post-licensure Credentialing of Pharmacists, August 2020. Adopted by the Council on Credentialing in Pharmacy Washington, D.C. Revised and approved: August 6, 2020. http://www.pharmacycredentialing.org/Files/GuidingPrinciplesPharmacistCredentialing.pdf. Accessed on February 10, 2021.
- Council on Credentialing in Pharmacy. Credentialing and privileging of pharmacists: A resource paper from the Council on Credentialing in Pharmacy. AmJ Health-Syst Pharm. 2014;71:1891-1900. https://doi.org/10.2146/ajhp140420.
- Merrigan D. Internal approach to competency-based credentialing for hospital clinical pharmacists. Am J Health-Syst Pharm. 2002;59:552-558. doi: 10.1093/ajhp/59.6.552.
- Abramowitz PW, Shane R, Daigle LA, Noonan KA, Letendre DE. Pharmacist interdependent prescribing: a new model for optimizing patient outcomes. Am J Health Syst Pharm. 2012; 69:1976-1981. https://doi.org/10.2146/ajhp120546.
Week 4
Step 4. Define the Services You Plan to Provide to Medicaid Patients as a Medical Provider
Determine What Services You Already Provide and What Services You'd Like to Provide
- Start with the big picture and determine what your "why" is for offering services that can be billed to Medicaid.
Questions to Ask Your Team
- How will Medicaid provider status benefit your patients?
- How will Medicaid provider status benefit your staff?
- How will Medicaid provider status benefit your organization/practice?
Evaluate and Understand Medication-related Gaps and Opportunities within your Service Area
- What problems could you solve by implementing provider status?
Be Prepared to Show your Value with Defined, Achievable, and Meaningful Metrics
- Clinical metrics (e.g., hemoglobin A1C, hypertension goals)
- Population metrics (e.g., access to care)
- Wellbeing metrics (e.g., provider burnout and retention)
Week 5
Step 5. Meet with Credentialing, Compliance, and Billing Departments
Your organization may have a compliance department that offers guidance on billing practices to ensure that the claims you submit are appropriate, accurate, and legal. Proactively providing key compliance personnel information about 2021 Wisconsin Act 98 , DHS 105 , and DHS 107 will help to prevent limits to the types of services for which pharmacists can be reimbursed within your organization. If feasible, consider developing a provider status implementation team within your organization. Additional members may include IT, billing, quality, medical staff, accounting, and revenue cycle management. Each organization is unique, and these departments will ask the questions that will need to be resolved along the road to implementation. Visit PSW’s provider status resource page for billing and other resources.
Week 6
Step 6. Show Your Value with Defined, Achievable, and Meaningful Metrics
Watch this 1-hour Leveraging Quality Metrics to Highlight the Impact of Ambulatory Care Pharmacy CE to help outline the defined, achievable, and meaningful quality metrics you can use to show your value to important stakeholders inside and outside your organization. Pharmacists from three organizations describe their experience in outlining quality metrics during service implementation.
Click here to register.
Week 7
Step 7. Gather Materials in Preparation for Medicaid Enrollment and Credentialing
Medicaid Fee For Service (FFS) pharmacist provider enrollment is currently planned to open in Spring of 2024. In preparation for this process, Wisconsin Medicaid has provided a list of items that will be required to complete the online enrollment process. Additionally, Wisconsin Medicaid recommends reviewing the Enrollment Application and Tracking Process. Information about pharmacist provider credentialing and contracting with each of the Medicaid HMOs will be provided when available.
- Wisconsin pharmacist license information (any other license will not be accepted)
- Social Security Number
- Disclosure of whether the provider has any owner/controlling interests in their location.
- Pharmacist’s organization’s NPI (if employed by a clinic)
- DEA # (if applicable)
- Tax information including Taxpayer’s Identification Number (TIN) and the effective dates
- Either an Employee Identification Number or the individual’s SSN can be used for the TIN.
- Providers will need to attest if they are working under a collaborative practice agreement (CPA).
- Once enrolled, providers will be responsible for updating the Demographic Maintenance tool when there is a change in collaborative practice agreement status.
Week 8
Step 8. Review Wisconsin ForwardHealth Training Resources
To generally prepare for billing medical claims through ForwardHealth, Wisconsin Medicaid recommends that pharmacists watch the following videos located on the ForwardHealth Portal: