Hospice Providers, it’s time to take your head out of the sand! Medicare keeps writing long memos about who pays for what medications and I still keep hearing that the hospice only pays for pain medications. The information below was taken from the Medicare Memo issued last week.
- You don’t get to exclude all meds and care not directly related to the terminal condition. Supposedly this has always been the case.
- You cannot exclude medications that are used for the comfort and palliation of symptoms no matter what. If a patient is admitted for end stage heart failure and has arthritis, you must pay for arthritis medications as well.
- Prior authorizations for Medicare Part D will be required and they must include the reason why the medication is not covered under the hospice benefit.
- Medications that are paid for after the patient elects the hospice benefit but before the pharmacy has been notified will fall into some sort of limbo land and the pharmacy will have to collect from the hospice – or the patient. Any UFC fans out there?
- If a patient wants a specific drug that is not one your formulary and the patient refuses to try medications that are on your formulary, you can refuse to provide them. Alternatively, you can provide them and bill the patient if you have a signed advanced beneficiary notice.
- Patients have the right to appeal your decision.
If you want to survive this maze, the first thing you need to do is to approve a formulary. This is a list of drugs you may potentially be required to provide over and above the standing orders for pain meds. Personally, I would start with one of those $4.00 drug lists from a chain drug store. They all have one.
Hospice nurses must have frank discussions with patients and caregivers at the time of admission. In truth, there is no way to determine if a medication is for palliative relief of symptoms until the patient is assessed. In talking with patients and caregivers, the emphasis should be on symptoms. Some individuals with diabetes are very uncomfortable when their blood sugar goes up beyond a certain point. Other people can sport a blood sugar of 550 without symptoms. Blood pressure is usually asymptomatic but strokes are not. If a patient has suffered a prior neurological insult, the safest thing to do would be to find a cheap drug and treat it for less than 10.00 per month.
Nice hospice providers will alert their contracted pharmacy to a hospice admission as soon as it is known for sure that a patient will be admitted. This will prevent those limbo drugs where everyone is fighting over who pays. This process is recommended but not mandated (I think…) in the new CMS guidelines published last week.
People are funny about their medications. If a patient refuses to try Prilosec and opts for Dexilant at 20 times the cost, work with the patient. Ask for samples and assist the patient in getting the best price for the medication of choice.
Maybe the most disturbing aspect of the new guidance from CMS is the involvement of the patient and families. Part D pharmacies are advised to bill family members for medications that were inappropriately filled. Hospices with limited (if any) formularies will attempt to pass the cost off to the patient. Although the patient has the right to appeal the logistics of a hospice patient or family member appealing to Medicare strike me as utterly incongruent with the fundamental purpose of hospice which is to allow a patient to die at home in peace.
I have not seen as yet the proposed consequences to a provider who simply tells the patient Medicare won’t cover something without explaining all of the details, alternatives, etc. I think good hospices will put a blank appeal form in the home folder for the patient. Bad hospices will go out of their way to avoid telling patients and family members that an appeal is possible.
Meanwhile adopt a comprehensive formulary and start today advising the patient what you will pay for, the reason it will given (comfort) and what you will not be giving. It may cost you a few patients but I guarantee those that don’t put these processes into place will lose more than a patient or two.
Good luck with all this, you hear?