An Update on Vaccines for Hospice Patients
February 12, 2014 10:49 AM
In October 2013 CMS released Change Request (CR) 8098 which prevented non-hospice providers from furnishing vaccines (flu, pneumonia, and Hepatitis B) to hospice beneficiaries. Under CR 8098 hospices were responsible for providing the vaccines and non-hospice providers could not be paid for vaccines they furnished to hospice beneficiaries. This CR was initially released in order to enforce the statement in the Medicare Claims Processing Manual (Pub.100-04), chapter 18, section 10.2.4 that vaccines "may be covered when furnished by the hospice".
CMS has determined that this enforcement is too restrictive, since the manual does not say "only when furnished by the hospice". Late last week CMS released CR 8620 that turns off the edits initiated in CR 8098 thereby allowing non-hospice providers to be paid for the vaccines they furnished to hospice beneficiaries.
The implementation date for CR 8620 is April 7, 2014. Non-hospice providers should either hold claims for vaccines furnished to hospice patients until after April 7, 2014 or request adjustments after this date to previously denied claims. A hospice that wishes to bill for the vaccines it has furnished to its patients must be a Medicare Part B roster biller.
NAHC and its affiliate, the Hospice Association of America, have weighed in strongly with CMS in advocating for hospices to be able to institution bill (so that hospices do not have to become Part B roster billers) and continue to advocate heavily for this change.
More information on the history of vaccines to hospice patients can be found in previous NAHC Report issues listed below:
May 15, 2013
October 22, 2013
December 12, 2013
January 17, 2014