Home Health & Hospice Week

Hospice:

Watch Out For Part D Payment Concerns

Forthcoming assessment tool gets a name.

You may soon find yourself on the hook for your patients’ drugs, even when you think they aren’t related to the patient’s reason for hospice.

The Centers for Medicare & Medicaid Services notes that Medicare Part D spending for hospice beneficiaries has increased from $331.3 million in FY 2012 to $347.5 million in FY 2016. “The current prior authorization (PA) has reduced Part D program payments for drugs in four targeted categories (analgesics, anti-nauseants, anti-anxiety, and laxatives),” CMS allows in the rule. “However … there has been an increase in hospice beneficiaries filling prescriptions for a separate category of drugs we refer to as maintenance drugs.”

So-called maintenance drugs include “those used to treat high blood pressure, heart disease, asthma and diabetes. These categories include beta blockers, calcium channel blockers, corticosteroids, and insulin,” CMS explains.

Even if they were used to treat or cure a condition before hospice election, they are no longer

indicated after hospice election unless they offer symptom or pain relief, in which case hospices should pay for them, CMS argues in the rule.

Consider CMS’s discussion of Part B spending an early warning, says Theresa Forster with the

National Association for Home Care & Hospice. Hospices should put the issue on their radar.

Hospices should make certain “that their processes … for ensuring that the hospice pays for medications related to the terminal prognosis are sound,” advises Judi Lund Person with the National

Hospice & Palliative Care Organization.

Other issues CMS addresses in the proposed rule include:

  • HIS submission. The threshold for timely Hospice Item Set submission kicks up to 90 percent as of Oct. 1, CMS reminds hospices. Beginning Jan. 1, “hospices must submit at least 90 percent of all required HIS records within the 30 day submission timeframe for the year or be subject to a 2 percentage point reduction to their market basket update for FY 2020,” the rule says.

Tip:You can check your HIS submission stats in your Hospice Timeliness Compliance Threshold Report in the CASPER system.

  • HEART. Soon it may be time to say goodbye to HIS and hello to HEART. Last year, CMS

noted it was planning an assessment tool for hospice, despite industry objections to the idea (see Eli’s HCW, Vol. XXV, No. 29). “We envision the hospice patient assessment tool … as an expanded HIS. The hospice patient assessment tool would include current HIS items, as well as additional clinical items that could also be used for payment refinement purposes or to develop new quality measures,” CMS says in this year’s rule.

The Hospice Evaluation & Assessment Reporting Tool is still in the early stages, CMS says. “As we move forward with the development of the HEART patient assessment tool, we will continue to keep the public informed of our progress and solicit input as we establish and finalize domains of care to include in the assessment, and as we move towards specific item wording and development,” CMS promises in the rule.

  • Diagnosis coding. Hospices are doing a much better job including relevant diagnoses on their claims, CMS says. “Analysis of FY 2016 hospice claims shows that 100 percent of hospices reported more than one diagnosis, with 86 percent submitting at least two diagnoses and 77 percent including at least three diagnoses,” the agency notes. That’s up from 49 percent of claims in 2014 including only a single diagnosis.

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