MTM – Medication Therapy Management

MTM (Medication Therapy Management) has been around for a little while now. However, it hasn’t really caught on like CMS expected. This may have something to do with their Medicare Part D program requirements.

Under 423.153(d), a Part D sponsor must have established a MTM program that:

  • Ensures optimum therapeutic outcomes for targeted beneficiaries through improved medication use
  • Reduces the risk of adverse events
  • Is developed in cooperation with licensed and practicing pharmacists and physicians
  • Describes the resources and time required to implement the program if using outside personnel and establishes the fees for pharmacists or others
  • May be furnished by pharmacists or other qualified providers
  • May distinguish between services in ambulatory and institutional settings
  • Is coordinated with any care management plan established for a targeted individual under a chronic care improvement program (CCIP)

Each Part D Sponsor is required to incorporate a Medication Therapy Management (MTM) Program into their plans’ benefit structure.  Annually, Sponsors must submit a MTM Program description to CMS for review and approval.  A CMS-approved MTM Program is one of several required elements in the development of a Sponsor’s bid for the upcoming contract year.

CMR vs. TMR

In addition, CMS requires documentation of a targeted patient CMR (Comprehensive Medication Review) performed at least once every 365 days, with an offer extended within the first 60-days of enrollment in the MTM program. A TMR (Targeted Medication Review) is to be performed at least quarterly. Each of these reviews comes with their own set of requirements. There are some key differences in the plans. The National Board of Medication Therapy Management highlights the differences below.

CMS summarizes the primary differences between CMRs and TMRs as follows:

Therefore, while the follow-up intervention that results from a TMR may be person-to-person, the TMR is distinct from a CMR because it is focused on specific actual or potential medication-related problems, and a CMR is a comprehensive, real-time, interactive medication review and consultation with the beneficiary to assess their medication use for the presence of medication-related problems and results in the creation of a written summary in CMS’ standardized format.

In conclusion, although we do employ pharmacists, we are not currently participating in an approved Medicare Part D MTM Program.

If you are interested in implementing a new MTM program, please review the resources below to determine your next steps.

MTM Resources:

UT – Internal Pharmacist Services Tip Sheet (Internal access only)

CMS MTM Contact List

The National Board of Medication Therapy Management

2024 Medicare Advantage and Part D Final Rule (CMS-4201-F)

5 Core Components of Medication Therapy Management Plan

Humana MTM Services