In July, the Centers for Medicare & Medicaid Services (CMS) released Change Request (CR) 8358, Additional Data Reporting Requirements for Hospice Claims. Mandatory reporting of these additional items begins with claims with dates of service on or after April 1, 2014, with voluntary reporting beginning January 1, 2014. The CR provides instructions to Medicares Administrative Contractors (MACs) and also revises Section 30.3 of Chapter 11 of the Medicare Claims Processing Manual.
While CMS has significantly reduced the data collection requirements over those it originally planned to collect, concerns remain over the burden associated with submission of prescription drug data. CR 8358 requires that hospices begin reporting injectable and non-injectable prescription drugs on their claims on a line-item basis per fill.
Over the counter (OTC) drugs are not to be reported on the claim. Hospices will also be required to report infusion pumps on a line-item basis for each pump order and for each medication refill. DME other than infusion pumps are not to be reported on the claim. Hospices will have to use pharmacy, National Drug Code (NDC) and DME revenue codes (e.g. 0250, 029X and 0636) on the claim in order to include this data. The NDC data includes the quantity of the drug filled. All the additional data added to the claim per this CR will appear on the Medicare Summary Notice (MSN) to consumers in the same manner as hospice visit reporting currently appears.
The National Association for Home Care & Hospices Hospice Association of America (HAA) is seeking additional information on industry concerns related to compliance with the reporting of prescription drug data on claims, and is making a brief surveyavailable for response.
All hospice stakeholders are encouraged to complete the questionnaire and submit their responses; the information we gather will be used in discussions with CMS related to the requirement. If you have any questions or comments, please feel free to contact Katie Wehri (Katie@nahc.org) or Theresa Forster (tmf@nahc.org).
