The Centers for Medicare and Medicaid Services (CMS) issued a new Change Request (CR) 13202 that makes revisions to the Medicare Claims Processing Manual. The change will require updates to the Fiscal Intermediary Shared System in order to notify Part D plans when a beneficiary elects hospice. The goal of this CR is to provide timely notification when a beneficiary enrolls in hospice so that Medicare Part D may enact edits that deny payment of drugs under Part D, when appropriate.

The impetus for the change comes from a report issued by the Health and Human Services Office of Inspector General (OIG) which found Medicare Part D paid $422.7 million for prescription drugs in 2016 that should have been paid for under the Medicare Part A hospice benefit. In the FY2024 Hospice Wage Index, CMS included an extensive RFI on hospice services including Part D drug benefits being inappropriately used for hospice beneficiaries.

LeadingAge’s comments on this stated, “We strongly encourage CMS to pursue additional program integrity measures as well as clear education to other providers who bill for services outside the hospice benefit when a patient has elected hospice services.”

This is a first step towards holding other providers of Medicare services accountable for additional billing outside the hospice benefit. However, LeadingAge also asked CMS to more clearly identify the types of drugs that would fall under the hospices responsibility vs those that could remain on a Part D plan benefit to avoid barriers to hospice access. The changes outlined in the CR will take effect January 1, 2024, and nightly reports of hospice elections will be automatically sent to Part D plans beginning April 1, 2024.