CMS Will Apply May 1 Part D/Hospice Guidance through CY2015
May 14, 2014 05:12 PM
On May 9, 2014 the Centers for Medicare & Medicaid Services (CMS) sent a memorandum to all Part D plan sponsors notifying them that CMS intends to continue the 2014 Part D hospice guidance issued on March 10 for calendar year (CY) 2014 through 2015. The memorandum is not yet available on the CMS hospice center web page.
In the memo CMS explains, “It was our intention to undertake future rulemaking and had planned to proposed regulatory changes to be effective for coverage year 2015. However, because many commenters on the December 6, 2013, guidance requested the opportunity to assist CMS in developing a standardized process for payment coordination between Part D sponsors and hospices, rather than propose changes we included in the 2015 hospice prospective payment system proposed rule a request for comments on the changes we are considering under Part D. Therefore, the purpose of this memorandum is to announce our intention to continue the 2014 Part D hospice guidance through 2015.”
In related news - and as reported previously on the NAHC Member Listserv - CMS recently posted a list of Hospice FAQs dated April 18 to the Hospice Center web page (under the “Coordination Benefits” section). The FAQs address questions raised by Part D plans in relationship to coordination of drug coverage and hospice care.
NAHC’s Hospice Association of America (HAA) has developed several tools to assist member organizations as they implement processes to help patients ensure timely access to prescribed drugs. Following is a list of items now available on the NAHC website (under Hospice Regulatory Resources) for use by member organizations:
Part D PA Process Explanation--provides background on the process CMS has advised Part D plans and hospices to use for establishing appropriate coverage responsibility for prescription drugs for hospice patients.
Hospice and Part D – Questions and Answers-- answers to members’ frequently asked questions.
Part D PA Process -- Tips-- suggestions to help ensure compliance with Part D PA requirements.
Part D PA Process Sample Admission Notice-- a sample admission notice that includes an explanation of the Part D PA process.
Part D PA Process SAMPLE Current Patient Letter-- a sample letter explaining the Part D PA process that may be used with existing patients.
CMS Final Guidance March 2014.
CMS Guidance December 2013.
For more on the continuing hospice/Part D issue, please see NAHC Report, April 29, 2014.