Understanding State Regulations and Advocating for Medically Integrated Dispensing

Christie Smith, PharmD, vice president of Pharmacy and Payor Strategy at Cencora, provides guidance on establishing a medically integrated dispensing practice. She discusses how state laws vary significantly in regulating pharmacy ownership and outlines key differences between Texas and California regulations. Smith also advocates for reconsidering restrictions on medically integrated dispensing to better accommodate patient care, and encourages engaging with policymakers and payers to explore value-based models that support integrated care.

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Q: How should pharmacies take the necessary steps to best implement these care models into their health care system?

Christie Smith: The first thing we have to figure out is your state law. Every state is different and the Board of Pharmacy or the Board of Medical Examiners govern how things are done. So for example, in Texas, where I'm from, you have to have a licensed pharmacy. So the practice has to invest in a pharmacists, probably a technician, and then all the things that a licensed pharmacy would need to comply with. However, in California, it's completely different. A pharmacy cannot be owned by a physician in California, but what the state of California decided to do was they would allow a medically integrated dispensary that would be under the physician's license. So there's those are the 2 extremes, and there's a lot of different scenarios in between those 2 extremes. That's the first step. So even if a physician wants to have a medically integrated dispensing practice, we got to defer to the law. Now, is the law always absolute, as you well know, laws change, and you have to be very visible in your community, to talk to your representatives, let them know your concerns, like for Rhode Island, I have found out there is not a provision for that in Rhode Island. Now, the heartbreak about that is these MIDs are not just for oncology, they're also for other specialties like rheumatology. So there's this one rheumatologist in Rhode Island, and we we have no way to help him. He wants to help his all patients, but the law prohibits a doctor or having a pharmacy under ownership. So I think we have to evolve with the times to accommodate the patient versus all the systems. So I think that's the first step that that a pharmacy would need to do, and then we just simply look at the number of physicians, the number of prescriptions that are being written, what drugs to see if it makes sense. If it doesn't make sense, then we're not gonna give you that recommendation. Then the next couple of steps is to get a contract with your drug distributor, and then start resourcing your staffing. It could be even staff in your office, say if it's a medical assistant, and they want to be trained on how to be a pharm tech, we have resources that can help you get there, and we have a wonderful association, NCODA, also trains pharmacy technicians.

Q: Are there specific resources or best practices that pharmacists should consider for their practice that are in line with these models?

Christie Smith: Payers often require you to have a certain accreditation, a quality standard that's uniform, and so typically, in this type of model, you'll need to either get ACHC accreditation, the Joint Commission accreditation, Yurek accreditation, and now NCODA accreditation. So it's just standards, guidelines, policies, procedures, to designate that you are practicing pharmacy as at the top of your game, best practice. That's a separate accreditation. It;s not any a part of any particular payer or drug distributor or manufacturer. It's just a stamp of approval that you practice at a high level.

Q: Is there anything else you would like to add?

Christie Smith: I was just having a conversation earlier today at a here at Asembia with some colleagues, and what I just want to say to you to the public is that we need to reconsider medically integrated dispensing, and the reason I think you want to do that is because site of care is is important. It wouldn't be that MID could be in every state as that as I kind of alluded to, but not only that, like there are some states where independent specialty physicians are not an existence like Boston. There are no independent community oncologist left there. They're all on by health systems and while health systems is an important part of our care spectrum. If we don't think differently about giving providers access to their health to their own patients, then we might be in trouble in the long run. So consider giving providers access to their own patients because the majority of those patients, 70% of those patients, are still going to have to go through a specialty pharmacy, like a mail order pharmacy, so we really are only talking about a small portion of patients so I would just do a call to action since I have the platform to insurance plans, plan sponsors that like implore groups, that if you have a high trend in oncology, other immunology disorders, consider asking your PBM about medically integrated dispensing.