CMS Holds Special Open Door Forum on Hospice and Medicare Part D
CMS held a Special Open Door Forum (ODF) on the topic of Medicare Part D and Hospice on April 8, 2014. This ODF was an opportunity for providers to ask questions of CMS subject matter experts on the Part D Payment for Drugs for Beneficiaries Enrolled in Hospice – Final 2014 Guidance. This guidance was released on March 10, 2014 and is effective May 1, 2014. Because previous Part D guidance was ambiguous, and there were no objective criteria for sponsors to use in making Part A vs. Part D coverage and payment decisions, the policy will be applied prospectively.
During the ODF CMS reminded providers that, per statute, Medicare excludes from coverage under Part D any drugs that are available under Parts A or B. Since hospice is a Part A benefit, drugs covered under the hospice benefit for an individual can not be covered under Part D.
In order to avoid duplicate payments for drugs covered under hospice or waived through the hospice election, CMS directed Part D sponsors to place beneficiary-level prior authorization (PA) requirements on all drugs presented to Part D for payment for beneficiaries who are receiving hospice services. More detailed information is found in the Part D Payment for Drugs for Beneficiaries Enrolled in Hospice.