Additional Organizations Sign Onto Part D Prior Authorization Letter
June 24, 2014 10:47 AM
On June 11, a letter with 27 organizational sign-ons, including AARP, NAHC, and NHPCO, went to CMS’ Administrator Marilyn Tavenner urging that she halt the existing Part D prior authorization processes until a better solution can be found. Since the original letter was sent, 18 additional organizations – including the American Medical Association – have offered their support and signed onto the letter.
Earlier this week, the original June 11 letter was again sent to Ms. Tavenner with the additional signatories. The letter urges that CMS put a, “halt to [CMS’ March 10 Guidance -- Part D Payment for Drugs for Beneficiaries Enrolled in Hospice—Final 2014 Guidance] until a workable alternative is developed that does not place the burden of resolving payment disputes squarely on the shoulders of terminally ill Medicare beneficiaries.”
The letter to Administrator Tavenner is the latest effort in recent months by NAHC and others to bring attention to the many problems arising out of CMS’ requirement that Part D plans implement a beneficiary-level prior authorization requirement on drugs prescribed for hospice-enrolled beneficiaries.
According to the letter, all the organizations:
“Appreciate that CMS seeks to ensure that the appropriate entity pays for medications, we believe this policy places an undue burden on hospice patients. Most importantly, we are concerned that the Guidance places the beneficiary at the center of potential disagreements between hospice providers and Part D plans—essentially requiring dying patients to navigate payer disputes. As such, we urge CMS to replace the Guidance with a more suitable solution. In particular, we strongly urge CMS to suspend the current policy directing Part D plans to place prior authorization requirements on all prescriptions for hospice beneficiaries. We request that CMS bring together all relevant stakeholders, including beneficiary advocates, hospice providers, Part D plans and pharmacists, to collectively work through these issues.
When a beneficiary elects hospice care under Medicare, the hospice is required to pay for drugs associated with the terminal illness or related conditions. Part D processes the medications for conditions unrelated to the terminal illness. As evidenced by a recent analysis from the Office of the Inspector General (OIG), medications that should be covered by the Medicare hospice benefit have sometimes been paid for by Part D plans. In an attempt to prevent this outcome, the Guidance requires all prescribed medications for hospice patients that are billed to Medicare Part D to be rejected for payment, by being subject to a prior authorization requirement.”
The letter concludes:
“Given the concerns outlined above, we believe the Guidance is premature, subject to differing interpretation, and already creating barriers for dying patients who are trying to access necessary medications. According to initial reports, some hospice patients are already paying out-of-pocket for their drugs, going without needed medication, or revoking their hospice benefit altogether in order to access their medicine through Part D.
In sum, we urge CMS to halt this Guidance until a workable alternative is developed that does not place the burden of resolving payment disputes squarely on the shoulders of terminally ill Medicare beneficiaries.”
To read the full letter – and see the full list of signatories, which now includes the AMA as well as NAHC, please click here.