Critical Steps in Hospice Medication Reporting
Posted On: February 8th, 2017
Senior Consultant, Optum Consulting
As it examines new reimbursement models, the Centers for Medicare & Medicaid Services (CMS) is looking closely at medication reporting by hospices. Although hospices are not currently being reimbursed separately for medications given, CMS is keen to gather data on the amount of money being spent per hospice patient per day, including medication.
Despite the complexities in hospice medication reporting, it’s important for hospice organizations to realize that Change Request (CR) 8358 is not a requirement without purpose—the more accurate the data CMS receives, the more sense future reimbursement levels will make.
Utilities like the pharmacy reconciliation functionality in McKesson Hospice™ can help ease some of the work related to accurate reporting, provided the tool is set up properly and understood by the users.
When setting up the tool, it’s critical to ensure:
- System options are entered
- Services maintenance (medication pump setup) is entered
- Revenue codes are set up on level-of-care services
- Access is granted to authorized users
- The hospice medication import is working with your pharmacy benefit manager (especially if you change vendors)
- You have a process to manually enter medications
Checking for errors
The pressure to send claims to payers in a timely manner is a constant within hospice organizations. Nevertheless, there are significant risks involved with sending claims that are incomplete or have errors. CMS has systems in place to check for multiple medication anomalies or errors at the organization level, which triggers a more detailed investigation.
Thus, accuracy is critical, even if it means delaying a bill. If you’re working with pharmacies that are consistently late submitting information, it’s incumbent upon you to explain the importance of timely submissions and work with them to reduce delays.
The pharmacy reconciliation utility can help you determine whether or not all medication information is being accurately pulled into claims. It allows you to filter your medication data by case manager, patient and error type. It also allows you to quickly check for missing information such as coverage, diagnosis, billable vs. non-billable medications and refill information.
Over the past few years, oversight regarding patient-pay medications has increased. There are, of course, still instances where a patient is on medication for a condition unrelated to the reason for his or her hospice stay. However, when CMS receives a Part D claim for a patient in hospice, it’s flagged as a possible error or potential for fraud.
Some hospices have adopted a policy of simply paying for all medications for their patients, regardless of whether or not it’s related to the terminal condition. Others continue to mark some medications as patient-pay but are careful to include the medication on all reports and document the reason for the exception.
Both approaches can work, but for those agencies choosing the latter, it is recommended that they exercise vigilance in documenting the exceptions and keep in mind that some exceptions (even well-documented ones) may be turned down by Medicare.
Regardless of the future of the Affordable Care Act, the wheels are turning toward value-based medicine, and medication reconciliation will continue to be a significant factor in achieving that goal.