NAHC/HAA Submit Comments on Preauthorization of Hospice Patient Drugs under Part D
January 14, 2014 12:52 PM
As previously reported, in recent months the Centers for Medicare & Medicaid Services (CMS) has accelerated activity related to coverage of drugs under Part D for hospice patients. The National Association for Home Care & Hospice’s (NAHC) Hospice Association of America (HAA) has been engaged in communication with CMS and other stakeholders on these issues.
Analgesics for Hospice Patients
CMS directed Part D plansto recoup payment for all analgesics provided to hospice patients, based on the presumption that any analgesic is for treatment of the terminal or related conditions. In response,HAA corresponded with CMS, expressing objection to the assumption that all analgesics prescribed for hospice patients are for the terminal or a related condition.
Preauthorization of Part D Drugs for Hospice Patients
In early December, CMS issued a memorandumdirecting Part D plans, effective March 1, 2014, to implement preauthorization processes for all drugs prescribed for patients on hospice. Last week, HAA submitted lengthy comments to CMS on preauthorization of Part D drugs for hospice patients.
Some key issues addressed as part of HAA’s comment are as follows:
Concerns about CMS’ interpretation of what is covered under the hospice benefit;
The need for CMS to confer with stakeholders on issues of determining relatedness;
Recognition that the hospice interdisciplinary group (IDG) is, as the clinical experts most familiar with the patient’s medical conditions, the unit most capable of ultimately determining what medications are and are not related to the terminal and related conditions;
Continuing objection to across-the-board recoupment of analgesics;
The need for CMS to direct Part D plans to cease across-the-board denial practices or requirements for prior authorization until such time as a coherent policy protecting appropriate and timely access to medications is developed and put in place (and no sooner than Oct. 1, 2014);
If preauthorization is implemented, CMS should develop a single process to be utilized by Part D plans;
Preauthorization should not be put into place until an independent review process with qualified individuals leading the effort is established;
Hospice and Part D plans should both be permitted access to independent review; and
CMS should first target for review hospices that have a history of numerous patients for which drugs have been inappropriately covered under Part D.
The NAHC/HAA comments provide greater detail on the above (and other) issues and is available for review here.
NAHC/HAA Seek Preauthorization Information. On a related matter, NAHC/HAA is seeking details related to incidence of Part D plans imposing across-the-board denial for coverage of drugs for hospice patients. This may or may not come in connection with Part D plans early implementation of preauthorization for drugs for hospice patients. Details regarding the names of the plans that are implementing such activity, whether or not the Part D plan has a clear preauthorization process in place, and information about the process, would be ideal, in addition to any information about delays preauthorization may be causing in patients getting needed medications.
Please submit the details to either Theresa Forster (firstname.lastname@example.org) or Katie Wehri (Katie@nahc.org.)