NHPCO NewsLine April 2014 - (Page 22)

Tip of the Month Part D Compliance: Where Do You Begin? O n March 10, 2014, CMS issued final guidance on "Hospice and Medicare Part D," as NHPCO shared in a Regulatory Alert. Per the CMS guidance, hospices will be required to complete a prior authorization with Part D plans for all medications unrelated to the patient's terminal illness and related conditions. To help providers prepare to respond to the prior authorization requirement, NHPCO also prepared a Compliance Guide, with details on nine key steps to take during the admission process: 7. Inform the patient or his/her representatives of liability and possible ABN 8. Inform the patient or his/her representative of appeal rights 9. Contact the patient's attending physician or other prescribers. In addition to providing details on the above steps, the Guide also includes a suggested process for reviewing a patient's medications once he or she elects hospice, as well as areas affected by the new regulation. Compliance Guide National Hospice and Palliative Care Organization Regulatory & Compliance www.nhpco.org/regulatory Incorporating Medicare Part D into the Hospice Admissions And Medication Managem ent Process Compliance for Hospice March 2014 Providers Hospice and Part D CMS issued final guidance on Part D and hospice on March 10, 2014. change admission and This final guidance will medication management processes in every hospice Medicare beneficiaries. that cares for This Compliance Guide provides hospice organizations with tools and suggested that will assist in compliance language with the Part D and hospice guidance. 1. Add appropriate language to the patient admission packet (sample language is provided) 2. Determine the patient's Part D coverage and identify his/her Part D plan 3. Describe the process to patients, representatives and families 4. File the Notice of Election as soon as possible 5. Proactively contact the Part D plan immediately upon admission 6. Review all of the patient's medications 22 NHPCO NewsLine Federal regulations at 42 CFR § 418.202(f) stipulate that the Medicare Hospice only drugs and biologicals Benefit covers used primarily for the relief of pain and symptom terminal illness and related control for the conditions (the term "drugs and biologicals" 1861(t) of the Social is defined in section Security Act). Download the Compliance Guide now. The recently finalized (March 2014) CMS guidance on Part D and hospice providers to adjust their will require hospice admission and medication management processes beneficiaries. Effective for Medicare May 1, 2014, Part D plan sponsors are required drugs billed to Part D to reject all prescription for beneficiaries who have elected the hospice hospice notifies the benefit unless or until Part D plan, through the a prior authorization unrelated to the terminal process, that the medication illness or related conditions. is Once the plan sponsor authorization for drugs processes the prior unrelated to the terminal illness, Part D will process will be responsible if the claim. The hospice the drug is related to the terminal illness or beneficiary may be related conditions, or financially responsible the if the drug is related hospice has determined to the terminal illness that it is not medically but the necessary. The hospice collect during the admission will have new data process, and increased to documentation requirements determination of relatedness for the and the completion of the prior authorization forms. Suggestions for hospice provider admission process when a patient has Part coverage D 1. Patient Admission Packet... Add language to your patient admission that the hospice provider materials that states is required to review all medications when the Medicare Hospice the patient elects Benefit. Sample language: As hospice providers, we need to meet the rules that the Centers and Medicaid (CMS) for Medicare set for us. As of May 1, 2014, if you have Medicare Part D © National Hospice and Palliative Care Organization, March 2014 Page 1 Updates Based on Your Feedback: As hospices begin making preparatory changes to their processes, nHPCo recognizes that additional questions and concerns will arise. Please relay your feedback to regulatory@nhpco.org - noting "Part D Communication Issues." the Guide will be updated accordingly. http://www.nhpco.org/regulatory-alerts/part-d-and-hospice-cms-final-guidance http://www.nhpco.org/files/compliance-guide-part-d http://www.nhpco.org/files/compliance-guide-part-d http://www.nhpco.org/files/compliance-guide-part-d http://www.nhpco.org/files/compliance-guide-part-d http://www.nhpco.org/files/compliance-guide-part-d http://www.nhpco.org/files/compliance-guide-part-d

Table of Contents for the Digital Edition of NHPCO NewsLine April 2014

Gaining as Much as They Give
A Message From Don
Dementia and the Hospice Volunteer
The Volunteer Management Mentorship Program
Volunteer Virtual Conference Sessions Now on E-OL
Celebrating Volunteers! (display ad)
NHDD Now 7 Years Strong
Help an Exemplary Volunteer Get National Recognition
Member News and Notes
Advocacy Intensive June 16-17 (display ad)
Compliance Tip: Part D
High-Performance Hospice Care (display ad)
Being a Member Can Save You Money (display ad)
Links to Resources on the NHPCO Website
A Feel-Good Moment
News From NHF

NHPCO NewsLine April 2014