Sometime in April, the Centers for Medicare and Medicaid Services (CMS)
will be posting a list of participating Competitive Acquisition Program (CAP)
vendors and the drugs they will supply on the CMS Web site at<www.cms.hhs.gov>.
After the information is posted, physicians who want to participate in the
program for 2006 will have 45 days to sign up. The program, originally
scheduled to begin on January 1, is now set to begin July 1.
CAP was mandated by the Medicare Modernization Act of 2003, which is also
responsible for the creation of the Medicare Part D prescription drug benefit.
The intent of CAP is to relieve physicians of the financial burden of having
to maintain expensive drug inventories for drugs they administer under
Medicare Part B, Medicare's outpatient coverage. Currently, physicians cannot
be reimbursed for Part B drugs until the drugs have been administered to a
patient and a claim is filed with Medicare for the service. Part B covers only
drugs that the patient does not self-administer. For psychiatrists, the only
drugs they are likely to administer are the long-acting injectable forms of
Physicians who sign up for CAP will be able to order drugs as needed from
the approved CAP vendor for the drug categories they have selected, and the
vendor will be reimbursed when the physician files a claim showing the drug
has been administered. Physicians who elect to participate in CAP must agree
to submit claims to Medicare within 14 days of the administration of a CAP
drug, using delineated CAP modifier codes on the claim. Election to
participate in CAP will be done on an annual basis.
In the case of emergencies, where there is no time to obtain the drug from
the CAP vendor, physicians can provide the drug from their own stock and
obtain a replacement from the vendor. If the CAP vendor does not stock the
drug, physicians can bill Medicare as before using the average sales price
method. There is some concern about how physicians will deal with the rule
that CAP vendors may deny drugs for patients who are more than 45 days late
paying their copays or deductibles.