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TO:     All Hospice and Waiver Providers

RE:     Concurrent/simultaneous services from Hospice and a Home and Community Based

            Services waiver- UPDATED Information about claims submission

The Alabama Medicaid Agency (Medicaid) updated the policy to allow concurrent services from hospice and a Home and Community-Based Services (HCBS) Waiver. However, it is vital that the hospice and HCBS waiver case manager coordinate to avoid duplication of services.

The HCBS waiver person-centered care plan (PCCP) and hospice plan of care (POC) of the recipient should be coordinated between the hospice, HCBS waiver case manager, and the recipient and his/her caregiver. A conference that includes these parties must be held before concurrent services can start. The PCCP/POC conference shall be documented in both the recipient’s hospice and waiver record. The PCCP/POC should specify all concurrent services, the frequency of services, and which entity will provide the service. Each HCBS Waiver service included in the PCCP/POC should have an explanation as to why the service is not covered under hospice.

Communication and coordination shall be ongoing and should occur on a regular basis. Written documentation in the recipient’s hospice and waiver record should reflect the communication and coordination.

As Hospice is a State Plan service, hospice benefits shall be fully utilized prior to waiver services to avoid duplication. Hospice is responsible for all services related to the recipient’s terminal illness. Both providers are subject to retrospective reviews of hospice and HCBS waiver services. If duplication of services is found, Medicaid may recover improper payment.

Examples of potentially duplicative services may include, but are not limited to:

• Hospice aide & HCBS personal care aide at the same time.
• Hospice medical supplies & HCBS specialized medical equipment.
• Hospice nursing care & HCBS Waiver skilled nursing at the same time.

Medicaid’s fiscal agent, Gainwell Technologies, will add the second provider to the level of care (LOC). Once added, both providers will be able to submit claims electronically, as usual.

However, until all system changes are complete, only the fiscal agent can update any information on the recipient’s LOC. That is, the waiver operating agency, Medicaid and Medicaid’s contractor will NOT be able to submit updates for the LOC. Medicaid will submit update requests to Gainwell. Providers will be notified when claims may be submitted.

If updates for a recipient receiving waiver services are needed, please send a request for action (RFA) Form 161B via secure email to: Jessie.burris@medicaid.alabama.gov.

If updates for a recipient receiving hospice services are needed, please send a Form 165B via secure email to

Cheryl.cardwell@medicaid.alabama.gov.

If you have questions, email Cheryl.cardwell@medicaid.alabama.gov or Jessie.burris@medicaid.alabama.gov.

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