CMS Posts Revised Part D Prior Authorization Form for Beneficiaries Enrolled in Hospice
February 6, 2015 03:55 PM
On Monday, February 2, 2015 the Centers for Medicare & Medicaid Services (CMS) posted a revised Part D Prior Authorization Form for Beneficiaries Enrolled in Hospice. CMS is now accepting comments on the form, and instructions and burden estimates until February 23, 2015. This revised form is the product of comments submitted to CMS at the end of last year. On October 3, 2014, CMS proposed a prior authorization (PA) form developed by the National Council of Prescription Drug Plans (NCPDP) Work Group 9 Hospice Task Groupconsisting, in part, of hospice industry experts. Comments on the proposed form were accepted through December 2, 2014.
The form proposed in October 2014 is a slight revision of one released in July 2014. The form is already in use by many hospices and Part D plans. This January 2015 PA form is the third iteration of the document. A PA form is required for processing of prescriptions through Part D for enrollees who also receive hospice care if the medication falls into one of these four categories: analgesics, antiemetics, laxatives and anxiolytics.
The form may be used in these situations where a PA is required, but is also used to communicate a change in the patient’s hospice status (i.e. revocation), as well as to communicate a medications listed on the hospice plan of care to the pharmacy/Part D plan. Absent a regulatory change, CMS cannot require the Part D plans to utilize a specific form. CMS, NCPDP, NAHC, NHPCO and other stakeholders, however, strongly encourage use of the form.
There are not many changes between this form and its instructions and the ones currently in use. A crosswalk lists the specific changes and is found via the link above. Instructions are clearer regarding how each provider is to use the form and complete the sections of the form. We continue to encourage hospices to use it proactively to communicate with the pharmacy/Part D plan regarding a Part D enrollee’s election of hospice care or change in hospice beneficiary status, provide information on any medications that are under any of the four categories of drugs that require PA, and to communicate the list of medications that are on the hospice plan of care. The Part D plan should accept this proactive communication, use it as necessary in situations where a PA is required, and patients should then receive their unrelated medications timely.
As previously stated, CMS is accepting comments on the revised form, instructions and burden estimates. Comments are due by February 23, 2015.
NAHC is compiling comments. To have your comments considered for inclusion, please send them to Katie@nahc.org or TMF@nahc.org