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NAHC Report: Issue# 2438, 5/28/2014
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Part D Regs for CY2015 Require Prescriber Medicare Enrollment, Address Improper Prescribing Practices
Proposed Revisions to Home Health Conditions of Participation sent to OMB for Review
For Your Information: Hospice Sessions at NAHC’s Financial Management Conference & Exhibition

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Part D Regs for CY2015 Require Prescriber Medicare Enrollment, Address Improper Prescribing Practices

On May 23, 2014, a final rule governing Medicare Advantage (MA) and Part D contracts for calendar year (CY) 2015 was published in the Federal Register.  The rule contains two changes in particular that could affect hospice physicians if they prescribe medications that are appropriately charged to patients’ Part D coverage, and these changes are summarized below. 

As part of its program integrity efforts related to Medicare Part D, the Centers for Medicare & Medicaid Services (CMS) has determined that, effective June 1, 2015, Part D plans may no longer cover drugs that are prescribed by physicians or other eligible professionals who are neither enrolled in Medicare nor have validly opted out of Medicare.

While many physicians that serve as hospice physicians are enrolled in Medicare, it is the understanding of the National Association for Home Care & Hospice (NAHC) that some hospice physicians are not. If these hospice physicians prescribe medications for Medicare beneficiaries that are unrelated to the hospice terminal illness or a related condition, and are appropriately covered under the patient’s Part D plan, it is advisable that these hospice physicians begin the process of either enrolling in Medicare in an approved status or of ensuring that they have a valid opt-out affidavit on file with an A/B Medicare Administrative Contractor (MAC).

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Post-Acute Care Bundling Payment Bill Introduced in the House

Representative David McKinley (R-WV) recently introduced H.R. 4673, the Bundling and Coordinating Post-Acute Care Act of 2014 (BACPAC) on behalf of himself and Rep. Price (R-GA). According to the legislation, the purpose of the bill is to:

  • Foster the delivery of high-quality post-acute care services in the most cost-effective manner possible;
  • Preserve the ability of patients, with the guidance of their physicians, to select their preferred providers of post-acute care services;
  • Promote competition among post-acute care providers on the basis of quality, cost, accountability, and customer service;
  • Achieve long-term sustainability by ensuring operational stability through regional breadth and the engagement of experienced care PAC coordinators;
  • Advance innovation in fields including telehealth, care coordination, medication management, and hospitalization avoidance; and
  • Provide for the financial security of the Medicare program by achieving substantial program savings through maximized efficiencies, cost avoidance, and outcomes improvement.

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Hospice Sessions at NAHC’s Financial Management Conference & Exhibition
July 13 – 15 in Chicago, IL

Below are some of the highlights from this year’s Hospice sessions at FMC:

Hospice Payment Refinement
This presentation will review the CMS proposed rule for Fiscal Year 2015 and model how the proposed rule will impact agencies.  The session will also look back at the FY 2014 proposed rule comments on rebasing the routine home care rate and the site of service adjustment, and will provide an overview of the payment reimbursement curve. 

Regulatory Change is Inevitable: Are We Prepared and What Will Medicare Learn from the Data?
The pace of regulatory and legislative changes in the hospice industry is at an all time high… his session will discuss the status of several regulatory changes that have or will occur in the hospice industry. We will discuss the additional burden placed on hospices to report additional patient-specific data elements, what impact it has on an agency and the industry and what Medicare will learn from this additional information.

Hospice Cost Savings: Finding Efficiencies
The outlook for 2014 Medicare home health and hospice rates are foggy at best with the threat of rate rebasing combined on top of the continuation of sequestration. Costs will continue to increase with new Medicare regulatory requirements, labor shortages, and modernization efforts in technology and delivery models…This program offers insights and ideas on successful ways to squeeze out even more efficiencies than you thought possible. Everything from back office costs to care utilization must be on the table for consideration. 

To see all of this year’s Financial Management Conference Educational Sessions, please click here.

To register to attend this year’s Financial Management Conference, please click here.

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