MTM Documentation Standards & Regulatory Compliance 2 — Questions and Answers
Question 1: Under HIPAA, which of the following constitutes a minimum necessary standard violation in MTM documentation?
- Recording only the medications reviewed during the CMR
- Sharing a patient's complete medical history with a billing clerk processing an MTM claim (Correct answer)
- Documenting allergies identified during the medication review
- Including the patient's phone number in the encounter record
Correct answer: Sharing a patient's complete medical history with a billing clerk processing an MTM claim
The minimum necessary standard requires limiting PHI disclosure to only what is needed for a specific purpose; sharing a complete medical history with a billing clerk exceeds that need.
Question 2: Which CMS requirement specifically addresses the timeframe for delivering a written Personal Medication List (PML) to the patient after a CMR?
- Within 24 hours of the encounter
- Within 7 calendar days of the encounter (Correct answer)
- Within 14 calendar days of the encounter
- At the time of the CMR encounter
Correct answer: Within 7 calendar days of the encounter
CMS requires that the PML and written summary be provided to the patient within 14 calendar days of the CMR, but the standard best practice and many plan contracts require delivery within 7 days.
Question 3: A pharmacist conducting an MTM encounter discovers a patient is using a medication not covered by their Part D plan. How should this be documented in the MAP?
- Omit it since it is not a covered Part D medication
- List it under the patient's complete medication list with notation of payment source (Correct answer)
- Only document it if it causes a drug interaction
- Flag it as an illicit medication use
Correct answer: List it under the patient's complete medication list with notation of payment source
The Medication Action Plan should reflect all medications the patient uses regardless of coverage status, with notation of cash-pay or other payer source.
Question 4: Which element is REQUIRED in the CMR written summary according to CMS MTM program guidelines?
- A list of the patient's insurance premiums
- Recommended laboratory tests ordered by the pharmacist
- A prioritized list of medication-related action items for the patient (Correct answer)
- The prescribing physician's DEA number
Correct answer: A prioritized list of medication-related action items for the patient
CMS requires the CMR written summary to include a prioritized list of medication-related action items, along with the PML and follow-up schedule.
Question 5: State pharmacy practice acts that govern MTM documentation most commonly require pharmacists to:
- Obtain prescribing authority before documenting therapeutic recommendations
- Maintain MTM encounter records for a minimum period defined by state law (Correct answer)
- Use only paper-based records for MTM services
- Submit encounter notes to the state board of pharmacy within 48 hours
Correct answer: Maintain MTM encounter records for a minimum period defined by state law
Most state practice acts require pharmacists to retain patient care records, including MTM documentation, for a minimum number of years specified by state law.
Question 6: When a pharmacist identifies a potential drug-drug interaction during an MTM session and documents a recommendation to the prescriber, which element is most critical to include?
- The patient's copay amount for each interacting drug
- The clinical rationale and supporting evidence for the recommendation (Correct answer)
- The pharmacy's NPI number
- The patient's marital status
Correct answer: The clinical rationale and supporting evidence for the recommendation
Documentation of the clinical rationale and evidence base for a prescriber recommendation demonstrates professional judgment and supports continuity of care.
Question 7: Which federal regulation requires MTM programs to be offered to beneficiaries who meet specific criteria related to chronic disease burden and medication use?
- The Medicare Modernization Act (MMA) of 2003 (Correct answer)
- The Health Information Technology for Economic and Clinical Health (HITECH) Act
- The Omnibus Budget Reconciliation Act (OBRA) of 1990
- The Drug Enforcement Administration (DEA) Practitioner's Manual
Correct answer: The Medicare Modernization Act (MMA) of 2003
The Medicare Modernization Act of 2003 established the Part D MTM program requirement, including eligibility criteria based on multiple chronic conditions, multiple medications, and likelihood of high drug costs.
MTM Documentation Standards & Regulatory Compliance 2
Under HIPAA, which of the following constitutes a minimum necessary standard violation in MTM documentation?