In late July, CMS issued Change Request 8358 (https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/Hospice/Downloads/R2747CP.pdf), imposing additional data reporting requirements for hospice claims. These reporting requirements are mandatory beginning April 1, 2014, and include reporting of prescription drugs (injectable and non-injectable) on a line-item basis per fill. The Hospice Association of America (an affiliate of the National Association for Home Care & Hospice) is seeking your input on challenges associated with meeting this new requirement. Additional information about CR 8358 is available in the July 31, 2013, issue of NAHC Report. If you have questions about this survey or comments that exceed the scope of this survey, please feel free to contact Katie Wehri (Katie@nahc.org) or Theresa Forster (tmf@nahc.org).

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* 1. Have you reviewed the additional data reporting requirements included in Change Request 8358?

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* 2. Is your hospice able to obtain the level of detail necessary from your pharmacy(ies) (i.e. units representing the amount filled) to comply with the new data reporting requirement?

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* 3. If you responded Yes to number 2 (above), are you working with the pharmacy(ies) to obtain the data at some time prior to the April 1, 2014, compliance date?

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* 4. If you answered Yes to number 2 (above), approximately how long will it take the pharmacy(ies) to be able to provide this level of detail?

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* 5. If you answered Yes to number 2 (above), does the pharmacy(ies) plan to increase its pricing so that it can provide data on its charge for prescription drugs on a per fill basis?

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* 6. If you answered No to number 2 (above) and your contracted pharmacy(ies) has indicated it cannot provide data on the charge for prescription drugs on a per-fill basis, do you plan to manually extract this information from the medical record?

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* 7. If you responded Yes to number 6 (above) how much manpower do you estimate it will take to gather the required per-fill prescription drug data and enter it onto the claim?

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* 8. Will your hospice need to delay claim submission in order to obtain this data each month? If so, do you have an estimate of the number of days by which your claims will be delayed in order to meet the requirement?

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* 9. If you utilize a software vendor for claims submission, has the vendor provided you with information about testing the additional data required on the claims and an anticipated timeframe for when their system will go "live" with this change?

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* 10. Do you anticipate any problems exceeding the allowable line limit on claims when submitting prescription drug information on a per-fill basis?

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* 11. Do you have any additional comments about this requirement?

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