MTM Documentation Standards & Regulatory Compliance 4 — Questions and Answers
Question 1: Under the MTM documentation framework, a 'follow-up plan' included in the CMR written summary must address which of the following?
- The patient's next pharmacy refill date for each medication
- Scheduled follow-up interactions and criteria for re-evaluation of drug therapy problems (Correct answer)
- The prescriber's next available appointment slot
- The plan sponsor's next annual enrollment period
Correct answer: Scheduled follow-up interactions and criteria for re-evaluation of drug therapy problems
CMS guidance requires the CMR written summary to include a follow-up plan specifying when and under what circumstances the patient should be re-evaluated for identified drug therapy problems.
Question 2: Which of the following best describes the purpose of an 'intervention' in MTM documentation?
- A mandatory referral to addiction counseling services
- A documented action taken by the pharmacist to resolve or prevent a drug therapy problem (Correct answer)
- A legal proceeding initiated against a prescriber for inappropriate prescribing
- A plan sponsor's denial of a medication prior authorization
Correct answer: A documented action taken by the pharmacist to resolve or prevent a drug therapy problem
An intervention in MTM documentation records the specific action the pharmacist took—such as contacting a prescriber or counseling a patient—to address an identified drug therapy problem.
Question 3: OBRA '90 requirements most directly influenced MTM by establishing the mandate for pharmacists to:
- Bill Medicare Part B for cognitive services
- Conduct prospective drug utilization review and offer patient counseling (Correct answer)
- Document all prescriptions in a centralized federal database
- Obtain collaborative practice agreements before counseling patients
Correct answer: Conduct prospective drug utilization review and offer patient counseling
OBRA '90 required pharmacists to conduct prospective DUR and offer counseling for Medicaid patients, laying the professional and regulatory groundwork for modern MTM services.
Question 4: A pharmacist submits an MTM claim using CPT code 99605. This code is most appropriately used for:
- A follow-up MTM service with an established patient, 15 minutes
- An initial MTM service with a new patient, face-to-face, up to 15 minutes (Correct answer)
- A telephone-based TMR of any duration
- Group MTM education sessions with four or more patients
Correct answer: An initial MTM service with a new patient, face-to-face, up to 15 minutes
CPT 99605 is designated for an initial MTM encounter with a new patient, face-to-face, for up to 15 minutes, and is distinct from follow-up or telephone-based service codes.
Question 5: Which of the following situations requires the pharmacist to file a breach notification under HIPAA?
- A patient's MTM summary is mailed to an incorrect address and the error is discovered before delivery
- A pharmacist inadvertently emails a patient's MTM summary to the wrong patient and the error is not immediately correctable (Correct answer)
- A pharmacist discusses a patient's MTM results with the patient's care team
- A covered entity performs a routine internal audit of MTM records
Correct answer: A pharmacist inadvertently emails a patient's MTM summary to the wrong patient and the error is not immediately correctable
An impermissible disclosure of PHI that cannot be mitigated triggers HIPAA breach notification requirements to the affected individual and, depending on scale, to HHS.
Question 6: In electronic health record (EHR) integration for MTM, which documentation practice best supports interoperability with prescribers' systems?
- Using proprietary pharmacy software codes exclusive to the MTM platform
- Documenting clinical findings and recommendations using standardized terminologies such as SNOMED CT or RxNorm (Correct answer)
- Scanning handwritten notes as unstructured image files
- Limiting documentation to free-text narratives without coded data elements
Correct answer: Documenting clinical findings and recommendations using standardized terminologies such as SNOMED CT or RxNorm
Using standardized terminologies like SNOMED CT for diagnoses and RxNorm for medications enables structured data exchange between pharmacy and prescriber EHR systems.
Question 7: Which element of an MTM encounter record provides the strongest evidence of patient engagement and shared decision-making?
- The pharmacist's credential abbreviations after their name
- Documented patient agreement or refusal of specific action items and the rationale discussed (Correct answer)
- The pharmacy's state permit number
- The date the patient's insurance coverage became effective
Correct answer: Documented patient agreement or refusal of specific action items and the rationale discussed
Documenting whether the patient agreed with or declined specific action items, along with the discussion rationale, demonstrates shared decision-making and patient-centered care.
MTM Documentation Standards & Regulatory Compliance 4
Under the MTM documentation framework, a 'follow-up plan' included in the CMR written summary must address which of the following?