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Defining Polypharmacy: Variability and Impact Polypharmacy, the concurrent use of multiple medications, lacks a universal definition despite its prevalence. It is commonly defined as the routine use of five or more medications, encompassing prescription drugs, over-the-counter (OTC) medications, herbals, and supplements.
As noted in our previous communications, while the NHC would prefer a more traditional Notice and Comment rulemaking opportunity that would ensure the Agency directly responds to stakeholder feedback, we welcome this opportunity to express our reactions to CMS’ thinking on the negotiation program. and Keating, N. link] xii Chino, F.,
To strengthen the proposal, the NHC recommends that CMS avoid implementing rigid definitions of overweight and obese. Instead, CMS should review Part D plan prior authorization criteria to ensure that plan definitions align with treatment guidelines and ICD-10 diagnosis codes, promoting consistency and alignment among providers and payers.
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