Delta Care Rx Comments on New Article Issued by the Inspector-General (OIG): Medicare Could be Paying Twice for Prescription Drugs for Beneficiaries in Hospice

Share Article

The Inspector-General (IG) at the U.S. Department of Health and Human Services (HHS) recently announced their discovery of evidence indicating that the U.S. Medicare program could be paying twice for prescription drugs for hospice beneficiaries: Once under the Medicare Part A Hospice Per Diem Payments and again under Medicare Part D. Hospice Pharmacy Solution provider, Delta Care Rx, summarizes this issue along with the company's opinion about how to remedy a complicated process that exists when trying to assure that medications are being adjudicated correctly to Medicare Part D or the Hospice when applicable.

www.DeltaCareRx.com

Hospice organizations that do not develop and promote such a process are literally asking for accusations of fraud, since it could be understandably suggested that the hospice benefits financially when prescriptions that should be paid for by hospice...

The Inspector-General (IG) at the U.S. Department of Health and Human Services (HHS) recently announced their discovery of evidence indicating that the U.S. Medicare program could be paying twice for prescription drugs for hospice beneficiaries: "Once under the Medicare Part A hospice per diem payments and again under Medicare Part D." The full article by the OIG is referenced throughout this press release and is located at: http://oig.hhs.gov/oas/reports/region6/61000059.asp

Additionally, according to the IG's article, hospice beneficiaries could also be unnecessarily paying co-payments for prescription drugs that should actually be paid under Part D.

Based on their discovery of duplicate payments, the IG has recommended to CMS that they develop a procedure to prevent duplicate payments from occurring.

In a surprise response, CMS rejected the recommendation made by the IG to develop procedures to prevent such double payments until “conclusive evidence” can be obtained.

Delta Care Rx's Dr. Mihalyo says "Conclusive evidence is plentiful on this topic. If CMS really wants to step up and correct this violation against U.S. taxpayer dollars being spent inappropriately, the task will be very simple. However, the development of a procedure to accurately identify or completely prevent the double payment described is rather complicated. The main reason for this is that each hospice patient is unique with respect to their diagnosis and comorbidities. Another piece that may be unique is the particular reason why each medication is being prescribed for any given patient. Numerous medications often used in end-of-life care have multiple therapeutic uses, thus the IG cannot simply assume that a particular medication is related to a particular hospice diagnosis."

"If and when CMS looks into the double payments, they may be shocked by what they find." According to other info found within the article, "the calendar year 2009 data examined by the IG revealed that Medicare Part D paid prescription costs for analgesia, anti-nausea, anti-emetic, laxative, and anti-anxiety drugs; as well as other higher cost prescription meds used to treat terminal diseases like COPD and ALS."

"It is likely that many of these drugs should have been covered under the per diem payments made to hospice organizations," says Mihalyo. "CMS may have to remind the IG that the types of drugs mentioned above are not always necessarily related to the terminal diagnosis of the hospice patient, although it is highly likely that the majority of these medications should in most cases be hospice covered."

"The stakeholders in the medication reconciliation and procurement process include at a minimum: The Patient, The Hospice, The Pharmacy and Medicare Part D. Additional stakeholders may include Medicaid and another third party commonly referred to as the Pharmacy Benefit Manager or PBM."

"When it comes to hospice, all PBM’s are not created equal. The ideal hospice PBM employs a team of PharmD’s available 24/7/365 to assist the hospice in the transition of care experience for patients. PBM’s have a responsibility to hospice clients to promote accurate assignment of who pays for what, since PBM’s too can benefit from incorrect billing of Medicare Part D. It allows their Hospice client to perceive that their hospice medication 'cost per patient day' is lower than it actually is or should be."

"Hospices should always select a PBM that DOES NOT receive rebates from the pharmaceutical industry. This is a must to ensure that the recommendations made to the Hospice by the PBM’s Clinical Pharmacists for hospice pay medications are not influenced by rebates available to the PBM from the pharmaceutical industry."

What can a hospice organization do to quickly deal with this dilemma?

Mihalyo emphasizes that "the hospice must first accept responsibility as a stakeholder to create an infrastructure within the hospice that allows an efficient and accurate medication procurement process on admission of a patient and throughout the course of hospice patient's care. Delta Care Rx refers to this as 'Building a Pharmacotherapeutic Support System' aka PSS."

"Hospice organizations that do not develop and promote such a process are literally asking for accusations of fraud, since it could be understandably suggested that the hospice benefits financially when prescriptions that should be paid for by hospice are billed to Medicare Part D."

"Hospices should demonstrate and document their diligence in this matter. The easiest way for a hospice to do this is to contract with Delta Care Rx, the only national hospice pharmacy billing provider that has a complete and proprietary practice model that includes safeguards against the incorrect and duplicate billing recently announced by the IG."

Explaining how Delta Care Rx is capable of assisting hospices in addressing this issue, Mihalyo noted that "Delta Care's proprietary practice model ensures that the Delta Clinical Pharmacist works directly with pharmacy providers to remind those entities of their responsibility to correctly bill the Hospice and Medicare Part D as applicable. This collaboration involves “real time or live monitoring” of all potentially suspect billing scenarios. There are many reasons why Delta Care Rx is successful in these endeavors. However, a key part is Delta Care's promotion of Hospice Focused e-Prescribing software within the drug ordering process. For clients across the country, Delta Care will even allow for the ordering of Schedule II Controlled Substances via an e-Prescribing application built into Delta's online suite of e-Tools starting in August 2012. This is use of a product pioneered to the hospice pharmacy industry ONLY by Delta Care Rx."

Mihalyo was clear in saying, "The issues identified by the OIG are multi-dimensional problems and must be immediately addressed by the hospice industry. Avoiding overdue attention to this problem will leave the door wide open for a federal correction (no pun intended!) The hospice industry, as the most vulnerable stakeholder, should accept the challenge of building a competent Pharmacotherapeutic Support System (PSS) and lead the way."

The above are main points observed in a release by Delta Care Rx. Find the article in entirety at http://www.DeltaCareRx.com

The official OIG report is posted at http://oig.hhs.gov/oas/reports/region6/61000059.asp

Every hospice administrator should take the time to read this revealing report.

Delta Care Rx will continue to advocate for the hospice industry, which certainly does not deserve to pay the price for future research and action taken against the industry for fraudulent billing practices.

Share article on social media or email:

View article via:

Pdf Print

Contact Author

Andrew J. Mihalyo
Visit website