Yet another set of data for your risk analysis: on April 30, 2015, the CMS released a 23-million record data set from Medicare’s Part D Prescriber Public Use File. While other CMS data sets have focused on provider remuneration (whether paid by manufacturers or Medicare itself), the Part D data focuses on physicians’ and other practitioners’ prescribing practices of drugs, which may well be linked to the Sunshine Act data showing whether a prescribing physician had a financial relationship with the drug’s manufacturer.
The Part D data shows aggregate counts of Medicare Part D original and refill claims by prescriber and by drug , and it shows the amounts paid by the Medicare Part D plan, Medicare beneficiary, government subsidies, and any other third-party payers. Because Medicare Part D payments generally go to pharmacies to reimburse for the pharmacy’s costs (cost of ingredients, dispensing fees, sales tax and administration fees ), the “drug costs” included in the Part D Data do not indicate a transfer of value of any kind to the prescribing practitioner. Nevertheless, the data reveals which drugs physicians are prescribing, and how often.
The Part D data allows for analyses such as the relative rank of drugs by utilization, by cost, by rate of brand name dispensing, by medical specialties in the Medicare program, and by geography. When coupled with the data on Sunshine Act payments and transfers of value, Part D data may be viewed as showing the results of the relationships between physicians and the pharmaceutical industry.
According to CMS, the Part D Data relates only to Medicare beneficiaries – not physicians’ entire practices; does not include over-the-counter medications or any prescriptions obtained outside of the Part D benefit; and does not indicate quality of care provided. These types of limitations, however, will likely not deter inferences by the press, relators, or the government about potential misconduct when they perceive links between physicians’ financial relationships with drug companies and their drug-prescribing patterns.