CMS is inviting comments on a recent memo clarifying the criteria for determining Medicare payment responsibility for drugs for hospice beneficiaries. CMS notes that hospice providers are expected to cover virtually all drugs for hospice beneficiaries during the hospice election. For prescription drugs to be covered separately under Part D when the enrollee has elected hospice, the drug must be for treatment of a condition that is completely unrelated to the terminal condition or related conditions. CMS expects drugs will rarely be covered under Part D for hospice beneficiaries; the Part D sponsor therefore should place beneficiary-level prior authorization requirements on all drugs for hospice beneficiaries to determine whether the drugs are coverable under Part D. The hospice provider will be responsible for coordinating with Part D plan sponsors to determine payment responsibility for those drugs it believes should be covered separately under Part D. The memo addresses additional mechanics of the policy, including how hospices and plans should address disputes regarding payment responsibility for particular drugs while CMS develops an independent review process. CMS will accept comments on its guidance until January 10, 2014.