MedPAC Urges Suspension of Part D Prior Authorization for Hospice Patients
Makes Additional Recommendations in Comments on FY2015 Hospice Payment Rule
June 27, 2014 01:20 PM
The Medicare Payment Advisory Commission (MedPAC) recently issued its comments on the Centers for Medicare & Medicaid Services’ (CMS) hospice proposed payment rule for fiscal year (FY) 2015. Among its recommendations is the suspension of the current requirement that Part D plans impose a beneficiary-level prior authorization (PA) process on coverage of drugs for patients enrolled in the Medicare hospice benefit.
While MedPAC supports the notion of mechanisms such as PA to ensure proper payment, the letter points to concerns about the added burdens on beneficiaries and their family members as justification for their recommendation, and suggests that CMS issue a regulatory proposal to establish an improved PA process as soon as possible. MedPAC believes that such a process should require coordination between hospices and Part D plans at the outset of care and that exceptions (or unrelated drugs) should be entered into the system at the outset. MedPAC indicates the goal should be to make the process as seamless as possible for the beneficiary and family. The National Association for Home Care & Hospice (NAHC) and its affiliated Hospice Association of America (HAA) will express similar concerns in its comments to CMS.
MedPAC also addressed several other issues in its comments, including:
Filing timeframes for notices of election and termination/revocation
Hospice aggregate cap
Relative to payment reform, MedPAC expressed its dissatisfaction that CMS has not proposed at least an initial step related to payment reform for the coming payment year. MedPAC continues to have concerns that the existing payment policy encourages some hospice providers to take patients onto service who they believe will have extended stays in order that the hospice reaps financial benefit. MedPAC’s comment letter also applauds CMS’ intent, as expressed in the proposed payment regulation, to address patterns of care gleaned from data gathered in pursuit of payment reform that raise program integrity concerns. MedPAC also makes specific recommendations as to how CMS might more effectively pursue these program integrity concerns given resource limitations.
MedPAC expresses support for CMS’ proposed timeframes for filing of notices of election (NOE) and notices of termination or revocation (NOTR), and has indicated that it believes the planned three days to be sufficient for hospices to comply.
MedPAC does express concern relative to CMS’ proposed requirement that hospices calculate their own caps within five months of the close of the cap year. MedPAC believes early calculation of caps could be subject to gaming and would not likely represent the full liability for many hospices that exceed the cap. As an alternative, MedPAC is recommending that CMS have the Medicare Administrative Contractors (MACs) perform an initial cap calculation and establish processes for reviewing cap calculations at a later date to ensure that full liability is addressed.
NAHC/HAA will also, as part of their comments, express concerns about CMS’ proposal relative to calculation of the cap.
MedPAC’s full comment letter is available here.