For more than a decade, the Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services Office of the Inspector General (OIG), and other policymakers have noted with concern the growth in Medicare spending outside of the hospice benefit, while patients are on hospice care. One area of particular concern is spending for Part D drugs while patients are on hospice care, which totaled nearly $500 million in 2019.
The National Association for Home Care & Hospice (NAHC) and other stakeholder groups have been working as part of the National Council of Prescription Drug Plans (NCPDP) Hospice Task Group to improve coordination between hospice providers and Part D plans to ensure appropriate coverage for prescription drugs while patients are on hospice service. Through those efforts, it has been discovered that a key problem area contributing to poor coordination between hospice providers and Part D plans is the length of time it takes for information about a patient’s hospice election to filter through CMS’ systems to Part D prescription drug plans. While it is estimated that it takes an average of 22 days for hospice election information to reach a Part D plan, it frequently takes much longer. As a result, it is believed that Part D plans may, without their knowledge or the knowledge of the hospice provider, be covering drugs that are related to the hospice terminal diagnosis or a related condition.
To address the delay in transmission of hospice election status information to Part D plans, the NCPDP Hospice Task Group has provided support to RelayHealth (CMS’ Part D Transaction Facilitator) and CMS in developing a pilot program under which copies of the hospice Notice of Election (NOE) and other notices related to hospice election status are transmitted via RelayHealth to the Part D plans. The pilot utilizes the 837I NOE transaction for communication of election information. RelayHealth estimates that under the pilot this information would be transmitted within two days (and potentially much less time) from the hospice to the Part D plan.
If the pilot is successful in its goal of reducing the time frame for transmission of hospice election status information to the Part D plans, future work may be initiated to explore the potential for transmission of hospice election status information using Direct Data Entry NOE transactions, as well as additional information between hospices and Part D plans, such as information regarding what drugs are the responsibility of the hospice under Medicare Part A.
Currently transmission of drug coverage information between hospices and Part D plans is conducted via fax and is an unwieldy process.
During the planning phases of the pilot RelayHealth worked with hospice EMR vendors (Axxess, MatrixCare, and Netsmart) and hospice clearinghouses (Axxess and Waystar) to develop mechanisms that support transmission of the 837I to RelayHealth. Now that the pilot is close to going live (scheduled to begin August 1), RelayHealth is also directly recruiting hospice providers interested in participating in the pilot. If your hospice is interested in participating, you must:
- Have the capability to generate Notice of Election (NOE, NOC, NOTR) Transactions in the electronic 837I format
- Have the ability to submit a copy of 837I transactions to RelayHealth
- Have the willingness to provide resources to assist during the pilot test initiative (per timeline)
- Provide contact and other agency information to RelayHealth
- Complete and return a Business Associate Agreement (BAA) and implementation form
RelayHealth has requested that hospices wanting to participate in the pilot take the following steps:
- Confirm with your EMR vendor that you have the capability to generate electronic NOE 837I file
- Submit the following information along with a BAA which can be found here: https://medifacd.mckesson.com/Hospice/Hospice-Providers/
- Agency NPI
- Organization Name
- Primary Contact First and Last Name
- Phone number
- Email address
- Method of NOE Electronic Submission (Clearinghouse or Direct)
- If you submit electronic NOEs through a Clearinghouse, provide the name of your clearinghouse
- Submit information to: firstname.lastname@example.org
In late June, NCPDP conducted a webinar about the Hospice Election Status NCPDP/CMS Pilot that outlined the pilot program. NAHC encourages hospice providers and other interested stakeholders to view the webinar to familiarize themselves with details of the pilot program. The webinar and slides are available at the following links: