In a Change Request (CR 8098) issued May 3, 2013, the Centers for Medicare & Medicaid Services (CMS) indicated that, effective October 1, 2013 - for implementation on October 7, 2013 - Medicare systems will prevent non-hospice providers from providing vaccines to hospice patients. While a hospice may provide influenza, pneumococcal, and hepatitis B vaccines to hospice-enrolled beneficiaries who request them, and may bill the Part B Carrier for both the vaccine and an administration fee, any other provider will be denied reimbursement.
Medicare systems previously did not have the ability to differentiate between claims for the vaccines submitted by hospices and other providers/suppliers. CMS has now established an edit to the Common Working File (CWF) that allows the Medicare Administrative Contractors (MACs) to reject claims submitted by non-hospice providers for vaccines provided to hospice beneficiaries. Issuance of CR 8098 has raised a number of questions; they include questions on how a hospice provider may become a Part B supplier in order to bill for vaccines. Following is information that has been gathered to help address outstanding questions.
How Does a Hospice Bill for Vaccines?
In order to bill Medicare for preventive vaccines, a hospice must be a participating provider with Part B, which requires enrollment using CMS Form 855B with the local carrier/AB MACserving the state within which the provider operates. Submission of the 855B allows the hospice to secure a Provider Transaction Access Number (PTAN) for Part B billing privileges. In many cases the local carrier/AB MAC will NOT be the MAC that processes hospice payment under Part A.
The hospice would also be required to complete a CMS-588 Electronic Funds Transfer (EFT) Agreement, CMS-460 Medicare Participating Physician and Supplier Agreement and submit a $532.00 (2013) application fee. CMS provider enrollment staff have instructed that a hospice should apply as a “mass immunizer” on the 855B; securing a supplier number as a “mass immunizer” will allow the hospice to bill for three types of immunizations -- Influenza, Pneumococcal and Hepatitis.
The vaccine and administration fee should be billed to the local carrier/AB MAC on the Form CMS-1500. Payment is made using the same methodology as if a hospice is a Part B supplier. Additional information may be sought from the local carrier/AB MAC serving the hospice’s state. Given that most hospices may not have a high volume of patients for which they can bill Medicare Part B, hospices may want to conduct a thorough analysis of the potential benefits and costs of becoming a Part B supplier for vaccine purposes. Because use of preventive benefits under Part B is encouraged, there is a waiver of deductible and co-insurance amounts for hospice patients receiving the flu and/or pneumococcal vaccine(s). Hospices wishing to bill for any of the three vaccines should review instructions in Chapter 18 of the Medicare Claims Processing Manual, Publication 100-04.
NAHC’s HAA staff has fielded calls from a number of hospice providers seeking clarification on CR 8098. Hospices have requested additional information regarding:
- Why a hospice patient’s attending physician may not provide and bill for preventive vaccines and is that policy specified anywhere other than in CR8098?
- Whether hospices are required to provide preventive vaccines if a hospice patient requests one; if such is the case, why could vaccines not be reimbursed under Part A?
- If vaccine administration is discretionary on the part of the hospice, why are no other options available to a patient who is interested in receiving the vaccine(s)?
- Is a hospice eligible for Medicare payment for preventive vaccines if the hospice patient to whom vaccines have been administered does not have Part B coverage?
It is NAHC and HAA’s understanding that the MACs and CMS are receiving numerous questions about vaccine administration and billing by hospices. HAA staff will continue to seek additional details about vaccine policies related to hospice patients and provide updates as they arise through NAHC Report, Hospice Notes, and on the NAHC Member Listserv.