Hospice is a Medicare Part A benefit in which hospice providers are responsible for the provision of all care related to a terminal diagnosis and comorbidities at no cost to the patient. This includes medications. While Medicare Part D plans may cover medications determined to be unrelated to the patient’s hospice enrollment, current regulatory guidance from the Centers for Medicare and Medicaid Services states that billing for unrelated services during hospice enrollment should be “exceptional, unusual and rare.”1
Common hospice pharmacy utilization management strategies include the below practices. Intertwined in these strategies is clinical decision-making integral to the palliation of end-of-life symptoms:2
- Strategic dispensing: Recognition of factors that go into the total cost of dispensing a medication, beyond the price of the medication itself, and implementing best practices to mitigate fees.
- Proactive prescribing: The placement of “as needed” medications in the patient residence anticipating future urgent needs for managing common end-of-life symptoms.
- Incorporating deprescribing tools: Resources, including algorithms and clinician & patient/caregiver education, that bring awareness to the benefits of dose reduction and/or stopping a medication, with the intentions of ensuring the use of the lowest, most effective dose while reducing side effects, drug interactions & pill burden, and focusing on goals of care and their continual evaluation.3
- Adhering to a hospice formulary: A hospice formulary is a continually updated list of medications, often customized by an organization, representing hospice clinician clinical judgment.
Hospice formularies encompass most medications commonly used in pain and symptom management however they are not intended to cover every medication a patient may need.4 Maintaining a formulary serves to familiarize clinicians with cost-effective medication therapy but should not be used as a means of restriction. Interrupting or switching therapy for the sake of formulary status and/or cost savings in the absence of patient symptom and medication history assessment may precipitate symptom exacerbation.
This article aims to provide scenarios when a pause to identify impact of switching therapy is necessary. The approach to identifying alternative medication necessity includes assessment of medication therapy, hospice formulary, and therapeutic alternatives.
MEDICATION THERAPY ASSESSMENT
Review the current patient medication list, including scheduled and “as needed” therapies, and confirm that each medication meets the following criteria:5
- Manages or palliates condition(s) identified in the hospice plan of care.
- Appropriate and clinically necessary for palliating pain and/or symptom management.
- Not a candidate for deprescribing. To rule out medications commonly targeted for deprescribing and those requiring continual reevaluation for continued benefit, see Table 1 for examples.
| Table 1: Candidates for Deprescribing6 |
| Targeted Medication(s) Cited Broadly in Deprescribing Literature
(includes examples, deprescribing rationale and links providing additional detail) |
Antimicrobials7,8
|
Dementia medications9,10
|
Inhalers (hand-held)
|
Oral hypoglycemics & insulins15,16
|
Proton pump inhibitors (PPI)19,20
|
| Require Frequent Evaluation for Continued Benefit and Care Goal Alignment
(includes examples, deprescribing rationale and links providing additional detail) |
Anticoagulants
|
Antiplatelet agents
|
Antiglaucoma eye drops
|
Blood pressure lowering cardiovascular medications
|
Immunosuppressants
|
Ivabradine (Corlanor®)
|
Overactive bladder medications22
|
Pancreatic enzymes23
|
Rheumatoid arthritis agents
|
Ranolazine (Ranexa®)
|
Thyroid replacement agents
|
HOSPICE FORMULARY ASSESSMENT
Determine which medications are on your hospice formulary and which medications are not on your hospice formulary. It is expected that a portion of hospice covered medications will fall outside of a hospice’s formulary and may precipitate review of cost impact and/or identification of alternative products.
Recognize, at this point in the decision-making process, the medication continues to be beneficial for pain and/or symptom management, aligns with patient goals of care, and is not a candidate for deprescribing, therefore it is the responsibility of the hospice to cover it.
For “non-formulary” medications, the next step is to identify therapeutic alternatives, if any.
THERAPEUTIC ALTERNATIVE ASSESSMENT
Therapeutic alternatives are products with different chemical structures but of the same pharmacologic or therapeutic class; usually with similar therapeutic effects and adverse reaction profiles when administered to patients in therapeutically equivalent doses.26,27
- Medications with an appropriate therapeutic alternative on formulary:
- Examples may include, however not limited to, antihypertensives, antihistamines, pain & discomfort medications (non-steroidal anti-inflammatory drugs (e.g., ibuprofen), opioids, muscle relaxers), benzodiazepines, sleep aids, oral & topical corticosteroids, and oral & topical antimicrobials.
- Formulary agents may provide the same therapeutic effect however be available in a different form:
- Release form (e.g., regular-release (Prozac®) vs. extended-release (Prozac® Weekly))
- Procurement process (e.g., compounded product (oxycodone 40mg/ml oral solution vs. commercially manufactured product (OxyFast® 20mg/ml oral solution))
- Overall form (combination product (e.g., lisinopril-HCTZ) vs. individual medications (e.g., lisinopril and HCTZ dispensed separately)
- Route of administration (e.g., oral (tablet) vs. rectal (suppository) vs. parenteral (intramuscular))
- Medications without an appropriate therapeutic alternative on your hospice formulary:
- Identify the most cost-effective therapeutic alternative regardless of formulary status.
- See Table 2 for scenarios where a viable therapeutic alternative may not exist or where it is not advised to substitute without care goal assessment and recognition of medical history.
| Table 2: Scenarios Where Substitution with Alternative Products Prompts a Pause First |
| Medical Safety Issues
Medication allergies and intolerances, adverse reactions, and drug-drug, drug-disease & drug-food interactions. |
| Specific Drug Needs
Brand-name necessity, inactive ingredient intolerance, or sensitivity requiring consistency with a specific generic manufacturer. |
| Patient Stability Interruptions
Patients who have undergone considerable trial and error of medications and titrations to reach stability (common with refractory neurological conditions such as epilepsy or mental health conditions such as depression and schizophrenia). |
Seizure Management27
|
Depression
|
Antipsychotic use, especially clozapine, in patients with a history of treatment resistant schizophrenia
|
| Unique Medication Class Needs
Conditions for which only specific medications are indicated and provide symptom relief. |
Pulmonary hypertension (PH)
|
SUMMARY
Hospice providers often use strategies like formularies, deprescribing tools, and strategic dispensing to manage medication costs, ensuring they align with palliative care goals and symptom management. Medications are reviewed to confirm their appropriateness, with certain drugs being candidates for deprescribing, such as antimicrobials, dementia medications, and oral hypoglycemics. If a medication is deemed necessary but non-formulary, providers must evaluate therapeutic alternatives or consider the best cost-effective option while assessing any risks or complications that may arise from switching therapies.
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CITATIONS
- Enclara Pharmacia. Hospices Can Manage Part D Audit Risks. Blog. June 25, 2024. https://enclarapharmacia.com/hospices-can-manage-part-d-audit-risks
- Enclara Pharmacia. Hospice Pharmacy Utilization Management Strategies Support Quality Care. Blog. Dec 9, 2022. https://enclarapharmacia.com/hospice-pharmacy-utilization-management-strategies-support-quality-care#
- Pruskowski J. Deprescribing. In: Palliative Care Network of Wisconsin. Apr 17, 2024. https://www.mypcnow.org/fast-fact/deprescribing/
- ASHP Guidelines on the Pharmacy and Therapeutics Committee and the Formulary System. Am J Health-Syst Pharm. 2021;78:907-918.
- National Hospice & Palliative Care Organization (NHPCO), now a part of the Alliance for Care at Home. Determination of Hospice Medication Coverage. June 2022. https://allianceforcareathome.org/wp-content/uploads/NHPCO-Medication-Flow-Chart.pdf
- Clinical Pharmacology [database online]. Tampa, FL: Elsevier/Gold Standard, Inc.; 2026.
- Jablonski L, Pruskowski J. Antimicrobial Therapy at the End-of-Life. In: Palliative Care Network of Wisconsin. Sep 8, 2025. https://www.mypcnow.org/fast-fact/antimicrobial-therapy-at-the-end-of-life/
- Enclara Pharmacia Palliative Pearls. Antibiotic Use: Decision-Making Guidance for Hospice Care. Feb 19, 2025. https://enclarapharmacia.com/palliative-pearls/antibiotic-use-decision-making-guidance-for-hospice-care
- Liao P, Perri GA, Deprescribing Cholinesterase Inhibitors at the End-of-Life. In: Palliative Care Network of Wisconsin. Sep 15, 2024. https://www.mypcnow.org/fast-fact/deprescribing-cholinesterase-inhibitors-at-the-end-of-life/
- Cholinesterase Inhibitors (ChEIs) and Memantine. In: Deprescribing Guidelines and Algorithms. Deprescribing.org. 2018. https://deprescribing.org/resources/deprescribing-guidelines-algorithms/
- Enclara Pharmacia Palliative Pearls. Dementia Medications & Deprescribing. Feb 27, 2023. https://enclarapharmacia.com/palliative-pearls/dementia-medications-deprescribing-a-revision
- Enclara Pharmacia Palliative Pearls. Reconsidering Pharmacological Interventions for Dementia. Oct 23, 2023. https://enclarapharmacia.com/palliative-pearls/reconsidering-pharmacological-interventions-for-dementia-in-hospice-and-palliative-care
- Enclara Pharmacia Palliative Pearls. Understanding Dyspnea in End-Stage COPD, Jul 19, 2024. https://enclarapharmacia.com/palliative-pearls/understanding-dyspnea-in-end-stage-copd-back-to-basics
- Enclara Pharmacia Palliative Pearls. Inhaled Therapy Palliative Pearls. Aug 23, 2022. https://enclarapharmacia.com/palliative-pearls/inhaled-therapy-palliative-pearls-a-review
- Jeffreys E, Rosielle DA. Diabetes Management at the End-of-Life. In: Palliative Care Network of Wisconsin. Jan 19, 2026. www.mypcnow.org/fast-fact/diabetes-management-at-the-end-of-life/
- In: Deprescribing Guidelines and Algorithms. Deprescribing.org. 2018. https://deprescribing.org/resources/deprescribing-guidelines-algorithms/
- Enclara Pharmacia Palliative Pearls. Diabetes Management Case Study, Jan 16, 2017. https://enclarapharmacia.com/palliative-pearls/diabetes-management-case
- Enclara Pharmacia Palliative Pearls. Switching or Deprescribing Insulins. Jun 23, 2022. https://enclarapharmacia.com/palliative-pearls/switching-or-deprescribing-insulins-when-how
- Greenfield A, Cook T, Pruskowski J. Management of Refractory Gastroesophageal Reflux Disease. In: Palliative Care Network of Wisconsin. Apr 17, 2025. https://www.mypcnow.org/fast-fact/management-of-refractory-gastroesophageal-reflux-disease/
- Proton Pump Inhibitors (PPI). In: Deprescribing Guidelines and Algorithms. Deprescribing.org. 2018. https://deprescribing.org/resources/deprescribing-guidelines-algorithms/
- Enclara Pharmacia Palliative Pearls. Approach to Blood Pressure Lowering Agents in Hospice Care, Jun 18, 2020. https://enclarapharmacia.com/palliative-pearls/approach-to-blood-pressure-lowering-agents-in-hospice-care
- Habib MH, Arnold RM. Urinary Incontinence in Palliative Care Settings – Part 2: Management. In: Palliative Care Network of Wisconsin. Aug 6, 2021. https://www.mypcnow.org/fast-fact/urinary-incontinence-in-palliative-care-settings-part-2-management/
- Garcia MA, Braun UK, Iman S, Poon I, Jackson L. Pancreatic Enzyme Supplementation for Patients with Pancreatic Cancer. In: Palliative Care Network of Wisconsin. Mar 6, 2025. https://www.mypcnow.org/fast-fact/pancreatic-enzyme-supplementation-for-patients-with-pancreatic-cancer/
- Enclara Pharmacia Palliative Pearls. Symptom Management of Rheumatoid Arthritis. Sep 17, 2019. https://enclarapharmacia.com/palliative-pearls/70195-2
- Enclara Pharmacia Palliative Pearls. Thyroid replacement Therapy in Hospice: Assessing Continued Benefit. Jan 13, 2022. https://enclarapharmacia.com/palliative-pearls/thyroid-replacement-therapy-in-hospice-assessing-continued-benefit
- Principles of a sound drug formulary system. In: Hawkins B, ed. Best Practices for Hospital and Health-System Pharmacy: Positions and Guidance Documents of ASHP. American Society of Health-System Pharmacists; 2018:233-236.
- Steinhoff BJ, Runge W, Witte OW, et al. Substitution of anticonvulsant drugs. Ther Clin Risk Manag. 2009 Jun 22;5:449–457.
- Enclara Pharmacia Palliative Pearls. Depression Management Case. Nov 22, 2022. https://enclarapharmacia.com/palliative-pearls/depression-management
- Enclara Pharmacia Palliative Pearls. Clozapine Therapy: Overview and Place in Hospice & Palliative Care. Oct 21, 2025. https://enclarapharmacia.com/palliative-pearls/clozapine-therapy-overview-and-place-in-hospice-palliative-care
- Enclara Pharmacia Palliative Pearls. Managing Pulmonary Hypertension in Hospice Care: A Revision. Nov 17, 2025. https://enclarapharmacia.com/palliative-pearls/managing-pulmonary-hypertension-in-hospice-care-a-revision