Hospice Patients, Part D Coverage and Analgesics
November 19, 2013 03:22 PM
In the November, 5, 2013 issue of NAHC Report information was provided concerning a Centers for Medicare & Medicaid Services (CMS) memo of October 30, 2013, to all Medicare Part D plan sponsors instructing them to recoup payment directly from hospices for prescription analgesics paid for by the Part D plan during dates in 2011 and 2012 when the beneficiary was enrolled in hospice. There was also coverage of Hospice/Part D issues in the October 24, 2013, issue of NAHC Report.
The National Association for Home Care & Hospice (NAHC) and its affiliated Hospice Association of America (HAA) are concerned about CMS’ blanket statement that all analgesics are presumed related to the terminal (or a related) diagnosis and instruction that case-by-case analysis to determine relatedness is not necessary. We are working on your behalf to share these concerns and dialogue with the appropriate parties on a reasonable approach to addressing payments by Part D plans that should have been paid for by the hospice.
HAA has sent a letter to CMS expressingserious concerns about the assumptions that underlie CMS’ instructions to Part D Plan Sponsors and cautioning against an across-the-board ruling that any class of drugs should automatically be assumed to be the responsibility of the hospice program when a patient is on hospice.
It is only through review of the individual patient’s plan of care and medical records that clear determination of responsibility can be definitively established. NAHC/HAA will continue to reach out to CMS officials on this matter. If hospices are having any issues with pharmacies, receive any requests from Part D plan sponsors requesting payment, preauthorization of hospice patient medications or information about hospice patient enrollment dates please contact us at Katie@nahc.org or email@example.com.
In the interim, hospices should take the following steps to ensure compliance with Medicare coverage requirements:
1. Implement or reinforce processes for medication review on each regularly scheduled hospice visit to ensure the hospice is aware of all medications the patient is taking. This is particularly important for patients residing in facilities.
2. Implement or reinforce processes for identifying related and non-related medications and communicating this information to the pharmacy and the patient/family.
3. Conduct routine audits to ensure documentation supporting non-related medications is clear and present in the medical record.
4. Conduct routine audits to ensure the pharmacy is billing hospice for ALL related medications.
5. Develop the same processes for supplies and other hospice-related items.