Hospice Association of America and State Hospice Associations Urge Revision to Hospice Vaccine Billing Policy
March 5, 2014 12:48 PM
In May 2013 the Centers for Medicare & Medicaid Services (CMS) issued Change Request (CR) 8098 under which, effective October 1, 2013, Medicare systems would reject claims for vaccines provided to hospice patients by non-hospice providers. CR8098 also reiterated existing CMS policy that hospices could only bill influenza, pneumococcal, and hepatitis B vaccines provided to hospice patients if the hospice enrolled as a Part B supplier.
In response to concerns raised by the National Association for Home Care & Hospice’s Hospice Association of America (HAA) and others, CMS recently issued CR 8620, under which, effective April 7, 2014, it will reverse the edits put in place by CR 8098.
CMS’ issuance of CR 8098 raised additional questions within the hospice provider community relative to the requirement that hospices may only bill for preventive vaccines if they are enrolled as a Part B supplier. On February 20, 2014, HAA and 40 state associations representing home care and hospice providers sent a letter to CMS requesting that it reconsider the policy requiring hospices to become Part B suppliers in order to bill vaccines.
The letter cites concerns about costs and regulatory burdens as justification for CMS’ reconsideration of existing policy, as well as the fact that other provider types in similar circumstances are not required to bill vaccines as Part B suppliers.
The full text of the letter, including the list of state associations that supported this regulatory change, is available here.
Further updates on this issue will be supplied in future issues of NAHC Report and Hospice Notes.