COVID-19 Information Update
Link to the National Coalition of Hospice & Palliative Care page https://www.nationalcoalitionhpc.org/covid19/
For provider and policy issues regarding MHD Clinical Services Programs, including Pharmacy, The Missouri Rx Plan (MORx), Psychology, Exceptions, and Medical Precertifications, email us at: email@example.com.
Questions and comments regarding any other issues should be directed to: ask.MHD@dss.mo.gov
The COVID-19 hotline number is 877-435-8411.
Missouri Medicaid has offered for MHPCA to answer any questions you may have about Hospice Medicaid during the time of COVID. These questions should be COVID specific and questions should come to MHPCA at my email: firstname.lastname@example.org. I will send a completed list to MO Medicaid to respond. The answers will be placed on the MHPCA website with a link from our newsletter. A good reason to open the newsletter! I hope you all take advantage if you need something answered.
MHPCA and MAHC made a Waiver Request to DHSS around State Statue Section 195.060
This is the response we received from DHSS:
LTCFs can ask for pharmacies to send them hospice “comfort packs” in advance.
The pharmacy sends it over as emergency stock for the emergency supply—and no patient name or prescription is needed.
If and when it is needed, the LTCF gets a physician’s permission, and then administers from the E-kit stock.
Un-used supplies after COVID can be returned to the pharmacy.
See BNDD Regulation 19 CSR 30-1.052 below:
19 CSR 30-1.052
(1) Long-term care facilities (LTCFs) and their suppliers shall maintain written records
of transfers of controlled substances from the supplier to the LTCF emergency kit.
(2) The records shall include the date of transfer; the name of each controlled substance,
the strength, dosage form and quantity; the name, address and controlled substance
registration number of the supplier and the name, address and controlled substance
registration number of the LTCF. Federal Drug Enforcement Administration (DEA)
official order forms shall not be used to record transfers of controlled substances to
LTCF emergency kits.
(3) No physician’s order or prescription shall be used for initial stocking or replacement of
controlled substances in the emergency kit. Controlled substances contained in the kit
shall be obtained from a pharmacy, hospital or practitioner who holds a controlled substances
(4) The administration and medical staff of the LTCF, in conjunction with the primary
supplier, shall designate in written protocols and procedures who may have access to the
emergency kit, who may administer controlled access to or administer controlled substances
from the emergency kit.
(5) Each administration of controlled substances from the emergency kit shall be based
upon a practitioner’s order and shall be recorded in an administration record separate
from the patient’s medical record. This administration record shall include: the date,
patient’s name, drug name, drug strength, dosage, ordering practitioner’s name and
name of the person administering the controlled substance.
AUTHORITY: sections 195.050 and 195.195, RSMo 1994.* Original rule filed April 14,
2000, effective Nov. 30, 2000. *Original authority: 195.050, RSMo 1939, amended 1971,
1989 and 195.195, RSMo 1957, amended 1971, 1989, 1993.
CONTACT REGION 7 for Individual Waiver regarding F2F
If you are unable to meet the F2F requirement due to inability to get in place audio AND video consider applying for an individual waiver with CMS. Our President just spoke with CMS Region 7 about this issue. She was told by Region 7 to ask for an individual waiver if you are experiencing this issue.
In order for us to further process individual 1135 waivers as quickly as possible, please make sure it contains the following information:
Full Address (including county/city/town/state) CCN (Medicare provider number)
Contact person and his or her contact information for follow-up questions should the Region need additional clarification
Brief summary of why the waiver is needed. For example: CAH is sole community provider without reasonable transfer options at this point during the specified emergent event (e.g. flooding, tornado, fires, or flu outbreak). CAH needs a waiver to exceed its bed limit by X number of beds for Y days/weeks (be specific).
Consideration – Regulatory requirements or regulatory reference that the requestor is seeking to be waived.
To keep up with the important work CMS is doing in response to COVID-19, please visit the Current Emergencies Website.
If you would like to submit an individual 1135 waiver, please send to: CMD@cms.hhs.gov. Once received, we can send your request for processing.