Ask a Medicare Part D plan how its Medication Therapy Management program is doing and you’ll hear a strong number: most targeted members who are supposed to get a review, get one. Ask what share of all Part D beneficiaries who could benefit from a review actually received one, and the number drops to roughly one in ten. Both numbers are real. They’re just answering different questions.
Here’s what the completion-rate evidence actually shows about how MTM is performing.
Two completion rates, one program
Confusing these two numbers is the most common mistake in casual MTM commentary, so it’s worth stating both clearly:
- Of all Part D beneficiaries who would qualify for a Comprehensive Medication Review under a consistent, simulated eligibility standard, completion rose from 4.4% in 2013 to 8.1% in 2015 to 12.6% in 2020 — a real improvement, and still a small fraction.
- Of beneficiaries a plan had already identified as eligible and targeted for outreach, 2022 data shows 83% completion for Medicare Advantage Prescription Drug plans and 54% for standalone Prescription Drug Plans, which alone covered 47.3% of all Part D beneficiaries that year.
(peer-reviewed CMR completion-rate study, PMC; Cooke et al., The Senior Care Pharmacist 2022)
Both are accurate. The 83% figure describes how well plans serve the narrow slice of members they’ve already flagged. The 12.6% figure describes what happens to everyone else — the much larger group who could plausibly benefit but was never counted as a target in the first place.
Why the headline number looks better than the underlying reality
Part of the improvement in the “targeted” completion rate is real service delivery. Part of it is arithmetic. CMS made CMR completion a Star Rating quality measure in 2016, and plans responded — partly by delivering more reviews, and partly by narrowing who counts as eligible in the first place. The share of plans requiring at least three chronic conditions to qualify rose from 80% in 2016 to 90% in 2019 (same study). A completion rate can rise because more people got served, or because fewer people were counted as needing service — and this one rose from some of both.
A completion rate can rise because more people got served, or because fewer people were counted as needing service. This one rose from some of both.
Who gets left out
The same research found the improvement wasn’t evenly distributed. Asian and Hispanic beneficiaries, and beneficiaries dually enrolled in Medicaid, had lower CMR completion rates throughout the study period, and the gap only partially narrowed after the 2016 Star Rating measure took effect (PMC11069085). A program-level statistic going up doesn’t mean the underlying access gap closed evenly — it can mean the same disparity persisted at a higher baseline.
The financial pressure underneath
MTM performance doesn’t sit in isolation from the rest of pharmacy economics — it’s one of the levers that affects a pharmacy’s exposure to DIR fee clawbacks, and DIR pressure is squeezing the independent pharmacies that fill a large share of Part D prescriptions. NCPA surveys of independent pharmacy owners found 66% reporting difficulty filling open positions in mid-2023, and by early 2024, 32% said they were considering closing that year over cash-flow pressure, with 93% saying they might drop out of Medicare Part D altogether if conditions continued (NCPA, June 2023; NCPA, February 2024). A quality program that depends on stable staffing is being run by an industry segment reporting real strain on staffing.
A largely-solved problem, and one that isn’t
Not every documented MTM complaint is still current. Before 2019, pharmacies routinely had to log into separate portals for different MTM vendors — historically Mirixa and OutcomesMTM — to see opportunities across different health plans. Cardinal Health’s 2019 acquisition and merger of the two into a single platform was explicitly meant to end that fragmentation (NASPA; NCPA). No current, sourced evidence in this research points to ongoing multi-portal fragmentation as an active complaint — it looks like a largely-solved, historical problem rather than a live one. The completion-rate gap and the staffing pressure above, by contrast, are current and well-documented.
What this does and doesn’t claim
This isn’t a claim that MTM doesn’t work, or that the program hasn’t improved — the targeted-completion trend and the platform consolidation are real progress. It’s not a claim about ConfirmMyMeds either: this product doesn’t deliver, schedule, or report MTM services, and makes no claim about MTM outcomes or completion rates. The narrower point, backed directly by the sourced numbers above, is that “how well is MTM performing” depends entirely on which denominator is being used to answer the question — and most public discussion of the program only ever quotes one of them.
ConfirmMyMeds is a working application. It asks the patient to confirm their clinic’s medication list before the appointment — outside the portal, with the bottles in hand — and returns what they confirmed, what they flagged, and what they never started, timestamped and attributed. It never writes to your record; the clinician decides what goes in the chart and what to do about a gap. We have no outcome data and make no claims about adherence or affordability outcomes. We’re looking for clinics to help us learn where it fails.
This article discusses Medicare Part D MTM program performance in general terms, using publicly available data, and is not medical or financial advice.