The deadline for the submission of public comments on a memorandum CMS issued last month that provides additional guidance regarding payment responsibilities for drugs administered to hospice Medicare beneficiaries has been extended from January 6 to January 10, 2014. The policy clarification currently has an implementation date of March 1, 2014.
 
CMS is trying to prevent drugs from being “inappropriately” billed under Part D that are primarily used to relieve pain and control symptoms related to the terminal condition and related conditions. These are already covered under the Medicare Part A per-diem payment to hospice, CMS contends. Decisions regarding payment for services that are unrelated to hospice care or not indicated for pain reduction and management of the terminal illness and related conditions are to be made on a case-by-case basis. CMS is directing Part D sponsors to require that the physician or hospice obtain prior authorization for use of all drugs for hospice beneficiaries to verify whether the drugs should be covered under Part D or fall under the Part A payment. CMS originally published guidance on this in a memorandum released on October 30, 2013.  But comments indicating that terminology in the memorandum was unclear, led to CMS’ issuance of the Dec. 6 memorandum on which it is now seeking comment. 
 
Comments on the Dec. 6 memorandum can be submitted  by email to PartDBenefitImpl@cms.hhs.gov, using the subject “Request for Comments: Part D Payment for Drugs for Beneficiaries Enrolled in Hospice.”  Comments will be accepted until 6 p.m. E.T., Jan. 10. The Dec. 6 memorandum is available at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/Hospice/Downloads/Hospice-PartD-Payment.pdf.