The use of pharmacogenomics as a tool for medication management and metabolic validation can be extremely valuable for Hospice caregivers and medical directors.
Metabolic Validation has specific medical necessity guidelines for Hospice utilization that are very different from Home Health, Physician Clinics and other medical settings.
Unfortunately, this tool is currently being promoted in ways that are not appropriate and can be financially and legally detrimental to a Hospice company. Things such as paying a physician for referral via a survey or registry for patient that could never meet the criteria that the OIG for CMS has warranted against; and billing for every panel or gene that is not appropriate for Hospice patients.
Proper Hospice Utilization:
- Testing results should be returned in 48 hours or less to provide benefit to hospice patients, but not ALL patients should be tested according to CMS medical necessity guidelines. Specific guidance from laboratory is needed.
- Each medication the Hospice patient is currently on should be considered and addressed with the results to ensure accuracy of implementation of testing results.
- Testing results should report on specific FDA, Drug manufacturer and NIH dosage guidance, drug-drug integration for current medications not related to their terminal diagnosis.
- Hospice company should NOT receive remuneration from the lab for patients that are referred for billing and physicians should not violate Stark law and be paid for lab referrals (OIG letter regarding survey and pharmacogenomics labs).
- Testing should cover a minimum of 18 different genes including receptor and transporter genes.
- Hospice company’s should pay nothing for supplies, shipping, billing or other. (If it is not billed with pre approved guidelines from CMS, Hospice company can be charged under the global fee for testing).
- A Hospice patient should never be billed for any portion of the testing under Medicare.
- Proper documentation with each requisition form outlining medical necessity for CMS justification.
PGx Medical is a proud partner of LeadingAge Oklahoma and works alongside the Oklahoma State Dept of Health – LTC Division to educate healthcare professionals on the proper usage of Metabolic Validation (pharmacogenomics). To learn more on metabolic validation in the Hospice setting, please contact us at 405-509-5112, info@pgxmed.com, or visit www.pgxmed.com.