Drug Topics launched its “Medical Billing Decoded” series this week with a conversation featuring Jennifer Griffin, PharmD, and Duane Jones of Harps Food Stores, and what they described is not a thought experiment about pharmacy’s future. It is a live, 39-location demonstration that the future is already here for the pharmacies willing to build toward it.
The Harps Story, in Full
Harps Food Stores operates 39 pharmacy locations across Arkansas, Missouri, and Oklahoma. Today those pharmacies offer test-and-treat services for strep and flu, oral contraceptive prescribing, A1C testing, and Medicare Part B-billed vaccines as standard services across the entire network.
None of that happened quickly. The Harps clinical services story started with point-of-care testing years before COVID-19, at a time when the demand for pharmacist-administered rapid tests was modest and the decision to invest in the infrastructure felt premature. When the pandemic arrived and demand for POC testing surged in a way that most pharmacies weren’t operationally prepared to meet, Harps was ready. The infrastructure built in the quiet years became the infrastructure that made Harps essential in the urgent ones.
That sequencing, investing in clinical and billing infrastructure before peak demand rather than in response to it, is the strategic lesson that generalizes beyond Harps. The pharmacies that had CLIA certificates when COVID-19 testing demand exploded in 2020 captured market share. The pharmacies now building Medicare Part B billing for vaccine administration and clinical services before the Main Street Pharmacy Access Act passes will capture market share when it does. The pattern holds.
Duane Jones framed the cultural reality of this implementation with the honesty that pharmacists considering this path need to hear: “Change is never fun, and it’s always a little difficult, but once they embraced it and got through the change piece of it, you can ask any of our pharmacists and all of our programs we’ve implemented, they would never go back to the way it was before.”
That arc, from resistance to competency to professional enthusiasm, is the standard implementation trajectory for every clinical program this newsletter has covered. The ADCES pharmacist who now manages a four-drug CKD protocol would not return to telling patients their kidney labs look fine and wishing them a good day. The pharmacist running a GLP-1 adherence monitoring program would not return to dispensing semaglutide without a structured counseling protocol. The Harps pharmacist doing test-and-treat for strep is not nostalgic for the days of handing the patient a physician referral and watching them leave.
The clinical work is better. The professional identity is better. The business model is better. The difficulty is in the transition, not the destination.
The 250-Service Threshold That Defines Financial Viability
This newsletter has cited the economic threshold that Pooja Babbrah and Seth Joseph named at the Total Pharmacy Solutions Summit, and the Harps story provides the specific operating context that makes that threshold concrete.
Below roughly 250 clinical services monthly, programs remain financially negligible. Above that threshold, repeatable workflows, economies of scale, and demonstrable ROI for service delivery make the program financially self-sustaining.
A pharmacy that conducts 10 A1C tests per month, 8 strep screens, 5 oral contraceptive consultations, and 7 GLP-1 adherence check-ins is delivering 30 clinical services per month. Those 30 services represent meaningful patient care. They do not represent a sustainable revenue stream. The billing overhead, the documentation time, the staff training investment, and the payer credentialing cost all require volume to justify.
The pharmacy that conducts 80 A1C tests per month, 60 strep screens, 40 oral contraceptive consultations, and 70 GLP-1 adherence check-ins across those same service lines is conducting 250 clinical encounters per month. At that volume, the billing infrastructure is generating revenue that covers its own overhead and contributes to the pharmacy’s financial model. The workflows are practiced enough to be efficient. The staff is trained enough to execute without extensive pharmacist involvement in each step. The payer relationships are established enough to produce consistent reimbursement.
The path from 30 to 250 doesn’t happen through marketing. It happens through the same systematic patient panel approach this newsletter has documented across the year: identify the eligible patients, structure the proactive outreach, build the prescriber referral relationships, and document the outcomes that justify the payer contract.
Harps reached 39 locations doing this across multiple clinical service lines simultaneously. A single-location independent pharmacy reaches 250 monthly clinical services through focus, not breadth, building one or two service lines to full volume before adding a third.
The Structural Argument That Makes This Not Optional
Every major pharmacy policy development of 2026 points in the same direction. The convergence is not coincidence. It is the market signaling where pharmacy economics is going.
The Medicare GLP-1 Bridge, covered in this newsletter’s July 1 issue, created the first Medicare coverage pathway for GLP-1 therapy specifically for weight management, at a $50 monthly copay with a clinical service coordination structure. Pharmacists embedded in the coordination layer of that program generate clinical documentation value that the program’s architecture rewards.
The CMS ACCESS Model, covered in the July 5 issue, pays organizations based on whether enrolled patients hit guideline-informed health outcome targets. Pharmacist-led care coordination for hypertension, diabetes, CKD, and behavioral health patients generates the outcome data that determines whether the participating organization receives full payment. The clinical service is the revenue driver.
The Main Street Pharmacy Access Act, covered following its House Ways and Means Committee passage in May, would create Medicare Part B billing rights for pharmacist-provided test-and-treat services tied to pharmacist credentials rather than pharmacy addresses. When it passes, the pharmacies already enrolled in Part B, already credentialed, already running documented test-and-treat workflows, will begin billing on day one. The pharmacies that haven’t built the infrastructure will spend the first 12 months of the new payment era catching up.
The FTC settlements with Express Scripts and CVS Caremark, covered in the PBM restructuring issue, establish precedent that PBM practices previously considered standard industry behavior constitute unfair competition under federal law. The cost-plus reimbursement transitions at Optum Rx and Cigna documented in that same issue make the dispensing margin trajectory explicit: acquisition cost plus a transparent dispensing fee, with no spread, no rebate obscuring the actual margin, and no favorable generic pricing subsidizing the rest of the operation.
In that dispensing environment, the pharmacy’s financial model depends on clinical service revenue to generate the margin that dispensing no longer produces. The pharmacies building that revenue now are the ones that will have it when the cost-plus dispensing model is fully operational.
The Code Infrastructure That Makes Medical Billing Real
The conceptual case for medical billing is clear. The operational barrier that prevents most pharmacists from starting is not conceptual. It is the specific mechanical knowledge of which codes apply to which services, how to document the encounter to support the code, and which payers reimburse which services in which states.
This newsletter has documented the specific billing infrastructure across multiple issues throughout the year. Here is the consolidated billing architecture that covers the highest-impact pharmacist clinical services.
Point-of-care testing: CPT codes 87880 for rapid strep, 87804 for rapid flu A or B, 87428 for flu A/B combined, 83036 for hemoglobin A1c, 82947 for glucose, and 82465 for cholesterol. These codes require CLIA certificate of waiver, which the CLIA summer lull issue detailed the application process for. Medicare Part B pays approximately $7 to $30 per test depending on the analyte.
Vaccine administration: CPT 90460 for the first vaccine component with counseling for patients through age 18, CPT 90471 for the first vaccine administration for patients 19 and older, and CPT 90472 for each additional vaccine in the same encounter. Medicare Part B reimburses vaccine administration at approximately $30 to $40 per administration encounter, separate from the vaccine product payment.
RPM services: CPT 99453 for device setup and patient education, 99454 for the device supply with daily recording, 99457 for the first 20 minutes of monthly clinical management, and 99458 for each additional 20-minute increment. This newsletter’s RPM issue documented the full monthly billing calculation: 100 enrolled patients generate $14,000 to $30,000 monthly in direct billing depending on engagement intensity.
MTM and comprehensive medication review: CPT 99605 for the initial MTM encounter (new patient, up to 15 minutes), 99606 for a new patient encounter over 15 minutes, and 99607 for each additional 15 minutes. Medicare Part D MTM programs pay pharmacies directly for comprehensive medication reviews and targeted medication reviews conducted under the Part D MTM program. The specific rate varies by plan.
CMS ACCESS Model coordination: G0676 for CKM cardiometabolic conditions, G0677 for musculoskeletal pain, G0678 for behavioral health. These codes, documented in the ACCESS Model issue, are the specific billing mechanism for ACCESS-participating organizations.
CLIA waiver point-of-care diabetic retinopathy screening: CPT 92229 for AI-based retinal imaging with autonomous interpretation. The diabetic retinopathy screening issue documented the $45.75 Medicare Part B reimbursement and the McKesson pilot program currently selecting participating pharmacies.
The First Service That Changes Everything
Every pharmacist who has built a clinical billing infrastructure describes the same experience: the first service is the hardest. Not because the code is complicated. Not because the documentation is onerous. Because the first service requires building every element from scratch: the workflow, the documentation template, the payer credentialing, the staff training, and the internal operational expectation that this is now part of what the pharmacy does.
The second service reuses the credentialing you built for the first. The third reuses the documentation infrastructure. The fourth reuses the staff training framework. By the fifth service, the operational pattern is established and adding a new service is a marginal extension of existing infrastructure rather than a ground-up construction project.
This is the Harps trajectory described across years of clinical service expansion. It is the Shields-UMass diabetes coaching trajectory described in the PLOS ONE study. It is the Geisinger RPM trajectory described in the ConnectedCare365 cardiovascular program. Each started with one service, built the billing and operational infrastructure for it, and expanded from that foundation.
The pharmacist who starts today is not starting a program. They are starting the foundation.
Your Action This Week
Identify one billable clinical service your pharmacy currently provides informally, without systematic documentation and without billing.
The candidates are everywhere. A pharmacist-led A1C test conducted at the counter and recorded in a paper log but never billed. A point-of-care strep screen performed for a symptomatic patient and documented in the pharmacy management system but not submitted to Medicare or commercial insurance. A structured GLP-1 adherence check-in conducted during a refill pickup and noted internally but not coded. A medication therapy management session completed over the phone with a high-risk patient but not submitted under MTM billing.
Pick one. This week, do two specific things.
First, identify the CPT or HCPCS code that applies to that service in your state. For most of the services listed above, the code is the same nationally. For state-specific services like pharmacist test-and-treat under a collaborative practice agreement, the applicable code may vary by the specific service and the prescribing authority structure. Your state pharmacy association can confirm the applicable codes for your specific state regulatory context.
Second, build a documentation template for that service that captures the elements required to support the code. Most clinical CPT codes require documentation of the patient’s presenting concern, the clinical assessment, the intervention performed, and the follow-up plan. A one-page template that structures those four elements for your specific service is the documentation infrastructure that makes billing consistent and defensible.
Those two steps, the code and the template, completed this week, are the foundation of your clinical billing program. The 12-month head start they represent over the pharmacist who starts next year is real. In a market where 300 pharmacies closed in the last 90 days and the pharmacies thriving are the ones with diversified clinical revenue, 12 months is a meaningful competitive advantage.
The pharmacy of 2030 will be built on medical billing. The pharmacists starting that build this week will own the market they’re building into.
Sources: Drug Topics (Medical Billing Decoded, Episode 1: Jennifer Griffin and Duane Jones, Harps Food Stores, August 2026), Drug Topics (Total Pharmacy Solutions Summit Coverage: Pooja Babbrah and Seth Joseph PHARMS Keynote, August 2026), CMS (Medicare Physician Fee Schedule: CPT Code Reimbursement Rates for Point-of-Care Testing, Vaccine Administration, and RPM Services, 2026), CMS (ACCESS Model G-Code Billing Reference, July 2026), AMA CPT Editorial Panel (Point-of-Care Testing Code Descriptions and Documentation Requirements), PTCB / ASHP (CLIA Certificate of Waiver Application and Pharmacy POC Testing Infrastructure), Pharmacy Times (McKesson Diabetic Retinopathy Screening Pilot and CPT 92229, June 2026), Drug Channels (Independent Pharmacy Revenue Model Analysis, 2025-2026)