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Ohio Medicaid files rules for pharmacist provider status

The Ohio Department of Medicaid (ODM) has officially filed the rules for how pharmacists will function as providers. You can access them here. This is the culmination of nearly two years of advocacy efforts following the passage of Ohio Senate Bill 265, sponsored by Senator Matt Dolan in the 132nd Ohio General Assembly. As a reminder, this is the bill which recognized pharmacists as providers and opened the door for pharmacists to receive reimbursement for patient care services. Once a bill is signed into law, there is often the need for government agencies to write rules or regulations around this new law. This is exactly the situation for pharmacist provider status. Pharmacists needed ODM to update their regulations in order to begin credentialing pharmacists and give them provider IDs in order to reimburse them for the services they are providing to Medicaid patients.

The filing of this rule sets Ohio up to be the next state that will begin broadly reimbursing pharmacists under their Medicaid system. However, notably different from other states, is that Ohio will be one of the first to begin reimbursing pharmacists without a legislative mandate. This is the result of strong OPA member advocates across the state who have reached out to their elected leaders over these past months, as well as OPA staff’s relentless efforts to work with Medicaid managed care organizations (MCOs) to get clinical service programs off the ground – notably with UnitedHealthcare (UHC) Community Plan of Ohio, Buckeye Health Plan, and CareSource so far. Thank you to all of those advocates who contacted their legislators through letters, meetings, social media, and phone calls!

ODM has been working on this rule throughout the summer and released an initial draft for comment in late June 2020. OPA, pharmacists, physicians, patients, and healthcare leaders provided feedback on this initial draft of the rule. Much of the feedback covered a request to ensure that the rule would be written as closely aligned as possible to the original intent of the legislature when they passed SB 265. Following the submission of these comments, the process for writing rules includes 1) ODM officially filing the rule with the Joint Committee on Agency Rule Review (JCARR); 2) a public comment period opening; 3) a public hearing; 4) the rule being finalized; and finally 5) the rule going into effect.

The pharmacist provider status rules have been filed and the public comment period is now open through November 30, 2020. The public hearing is scheduled for 11:00 AM on November 30, 2020 and can be accessed at Phone number: 1-614-721-2972; Teleconference Pin: 986766309#.

As a result of ongoing discussions with OPA and all the comments received on the pharmacist provider status rule in June 2020, ODM has made changes to the current draft of the rule. In a good faith effort, ODM has additionally been communicating with OPA regarding what changes the association would prefer to be made. ODM has been committed to listening to and including many of our recommendations in the current draft of the rule. This includes opening up the reimbursement of both services with and without a consult agreement, following the intent of the legislature. In combination with MCOs so willing to work with pharmacist providers, the current language included in this rule sets Ohio pharmacists up to be national leaders in provider status efforts. OPA is supportive of current language in the rule, as it aligns with the original intent of SB 265 and allows enhanced access for patients to pharmacists provided care.

We encourage pharmacists and students to review the rule. OPA will be submitting a comment letter on behalf of OPA members. If you have feedback you would like included in the comment letter, please email your thoughts to by November 20, 2020. Alternatively, if you submit a comment letter, or if you’ve asked other members of the healthcare team, leaders of your organizations, or patients to submit comment letters, please forward them to If you would like to send your own letter to ODM, please send them to by 11:59 PM EST on November 30, 2020.

We’d like to thank ODM Director Maureen Corcoran and her team for maintaining open dialogue and open minds in our efforts to implement the law. We’d also like to thank many of the MCO teams, who have been supportive of our efforts to refine the rules and get payment for clinical services off the ground even before the implementation of the rules.

If there are any questions about the rule or submitting comments, please contact

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