Determining Covered and Non-Covered Medications for Hospice Patients

Recorded On: 03/27/2019

Hospice care under the Medicare Hospice Benefit (MHB) has grown and changed significantly since the beginning of the benefit in the 1980’s. The number of patients served annually exceeds 1.5 million. Hospice payments exceed $17 billion a year. Both are expected to continue to grow. What was originally a program primarily serving cancer patients has changed to caring for patients with multiple conditions contributing to a terminal prognosis. Additionally, the creation of a Medicare Prescription Drug Benefit (Part D) has also introduced challenges to the system.

The complexities associated with the aforementioned changes and challenges has created a potential gap for hospices in their attempts at meeting CMS’ expectations of Medicare’s Conditions of Participation (CoPs). This gap is presented, by the Office of the Inspector General (OIG), as a vulnerability in the Medicare Hospice Program. Addressing these vulnerabilities is a major focus of regulators. While not the only vulnerability, duplicate payment for medications is of specific concern to the Center for Medicare and Medicaid Services (CMS) and the OIG.

This program will help attendees understand the history of CMS’ perspective on the provision (coverage) of medication to beneficiaries under the benefit, OIG’s concerns of duplicate payments and enable hospices to develop strategies to manage regulatory and financial risks associated with medication coverage decisions.

Topics covered in this webinar include:

  • Review and interpretation of near-term historical Part D spend for Medicare beneficiaries that have chosen the MHB and its impact on CMS Guidance
  • Examining macro trends in hospice utilization and exploring how they may impact medication use under the MHB
  • Review and case study demonstration of NHPCO’s Determination of Hospice Medication Coverage tool

Greg Dyke, RPh (Moderator)

Consultant

Gregory Dyke, RPh, is a Registered Pharmacist specializing in Hospice and Palliative Care Pharmacy practice. During his career he has started two hospice pharmacies, worked for or consulted for numerous hospices and served for many years as Vice-President of Pharmacy and New Business Development for a 300+ ADC hospice in the Chicagoland area. While there he was responsible for medication use practices, ran the Nurse Practitioner-based Palliative Care Practice as well as conceived and built, from concept through service delivery, their first Hospice Inpatient Unit.

For the past 10 years he served as President of Clinical Consulting for a national Hospice Pharmacy PBM where he created the division and was responsible for the design and management of clinical initiatives for the company and its hospice partners. This included education, clinical publications, formulary design and interpretation of the impact of CMS regulations on medication use and clinical practices in hospice.

Additionally, he has served as adjunct assistant professor to two Colleges of Pharmacy, and served as the pharmacy advisor to the NHPCO Regulatory and Relatedness committees, as well as a member of numerous formulary and pharmacy and therapeutic committees.

Greg is currently a Quality and Compliance Representative for a large, multi-state hospice provider and is an Independent Hospice Pharmacy Consultant.

He received a BS in pharmacy from the University of Illinois, College of Pharmacy and has practiced end-of-life care pharmacy since 1985.

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