Hospice & Medicare Part D
Update (06/30/2014): Thanks to the hard work of Hospice Advocates across the country, 75 Senators and 202 Members of the House of Representatives signed on to letters asking CMS to temporarily lift implementation of current Part D and hospice guidance and work collaboratively with relevant stakeholders toward a better policy solution. To view a complete list of all co-signers, click here.
When a patient elects hospice, the hospice provides all of the care related to the terminal illness and related conditions. Patients at the end of life may also have several different medical conditions with which they have struggled for years but are not related to the terminal condition. In these cases, the other medical conditions are not the responsibility of the hospice; they are the responsibility of the patient’s primary insurer, which is usually Medicare, and Medicare Part D for medications. In March 2014, CMS issued guidance to the Part D provider and hospice communities introducing a “prior authorization” process for how the two groups should determine who pays for which drugs once a patient enters hospice. Members of Congress have called for CMS to slow the process and convene the stakeholders to create the appropriate communication channels and processes for prior authorizations. However, CMS has provided little instruction and absolutely no infrastructure to ensure that hospices and Part D plans can successfully implement this process without impacting patient access to medications. NHPCO and HAN have developed the Policy Points video and many other resources for Advocates and allies to better understand this complicated issue.
NHPCO and HAN have also put together this interactive timeline to lay out the important dates, actions and compliance deadlines issued by CMS, NHPCO and Congress, as well as compliance deadlines issued by CMS.
- 7/24/14 Regulatory Alert: Revised Part D Guidance (NHPCO members only)
- 7/18/14 NHPCO Press Release: Part D Interim Guidance
- 7/18/14 CMS Revised Guidance on Part D
- 07/10/2014 Senate Special Committee on Aging Letter to CMS Administrator Tavenner
- 07/02/2014 Regulatory Alert – NHPCO Submits Comment Letter to CMS on FY2015 Hospice Wage Index Proposed Rule (NHPCO members only)
- 07/01/2014 Press Release: Part D Advocacy Efforts – An Update
- 06/30/2014 House Letter to CMS Administrator Tavenner
- 06/27/2014 Senate Letter to CMS Administrator Tavenner
- 06/25/2014 Press Release: CMS Convenes Part D Stakeholder Meeting
- 06/23/2014 Results and Analysis of NHPCO Part D Survey
- 06/23/2014 Letter from Senator Reid to CMS Administrator Tavenner
- 06/11/14 Stakeholder Community Letter to CMS (Updated 6/23/2014)
- 06/09/14 NHPCO Voices Concern with Part D Policy
- 03/11/14 NHPCO Regulatory Alert on Hospice and Part D (NHPCO members only)
- 3/10/14 CMS Final Guidance on Part D
- 01/22/14 Response from CMS to Letter from Congressmen Reed and Thompson
- 12/16/13 Letter from Congressmen Reed and Thompson to CMS
- 11/05/13 Letter from Senator Hatch to CMS
- Read NHPCO’s Press Release on the CMS Part D Clarification
- Letter from HAN’s Legal Counsel