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CMS HPMS Memo, Part D Payment for Drugs for Beneficiaries Enrolled in Hospice—Request for Comments (Dec. 6, 2013), preamble

activein force · 2013-12-06 – presentact-effective-date

Previous policy statements by CMS have addressed hospice and Part D sponsor requirements

regarding responsibility for the payment of prescription drugs under the Part A hospice benefit

and Part D. However, we have received questions indicating our policy statements are being

misinterpreted by some parties. Therefore, in this memorandum, we seek to clarify the criteria

for determining payment responsibility for drugs for hospice beneficiaries. The information

included below is a summary, and clarification, of previous Medicare Part A regulatory and sub-regulatory guidance on eligibility and scope of benefits for Medicare hospice services. Based on

these clarifications are new expectations for Part D sponsors to prevent duplicate payments for

drugs covered under the hospice benefit or waived through the beneficiary’s hospice election.

CMS continues to be concerned that drugs covered under the Part A Hospice Benefit are being

billed to Part D inappropriately. Analysis completed by Abt Associates, on behalf of CMS,

found that in 2010 there were 750,590 hospice beneficiaries enrolled in Part D. Of those hospice

beneficiaries, 14.9% received 332,988 analgesics through Part D totaling $12.9 million.

Analgesic billing appeared to be concentrated among certain types of hospices. Ten percent

(350) of hospices accounted for approximately 51% of Part D analgesic claims. These hospices

providers were typically for-profit, new, and/or rural. Furthermore, 50.3% of the analgesic

claims were for hospice beneficiaries residing in nursing facilities.

We are issuing this guidance for review and seek comment on whether your questions have been

addressed. Please submit your comments to the CMS Part D mailbox at:

PartDBenefitImpl@cms.hhs.gov, using the subject “Request for Comments: Part D Payment for

Drugs for Beneficiaries Enrolled in Hospice.” Comments are due January 6, 2014 by noon EST.

Previous CMS Policy Statements

History

CMS memorandum dated December 6, 2013, to All Part D Plan Sponsors and Medicare Hospice Providers: "Part D Payment for Drugs for Beneficiaries Enrolled in Hospice—Request for Comments".

Provenance

Source
cms.gov
Retrieved
2026-09-17
Edition
hospice-memos-2026-09-17
Content hash
64a336c86d213b9d2b3380d342ccd8b5b926734e4138a17298eac546d3d0401e
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CMS HPMS Memo, Part D Payment for Drugs for Beneficiaries Enrolled in Hospice—Request for Comments (Dec. 6, 2013), preamble · binding.law