Program Income & 340B Pharmacy Programs. Fungisai Nota, PhD, MPH, CCEP October 26, 2016

Transcription

1 Program Income & 340B Pharmacy Programs Fungisai Nota, PhD, MPH, CCEP October 26, 2016

2 By Click the end to edit of this Master session, text participants styles will be able to: Second level Recognize o Third level allowable uses of program income Review requirements of tracking and monitoring program income Discuss implementation of 340B pharmacies through RWHAP Develop strategies to spend down 340B program income

3 Click Fundamentals to edit Master of program text styles income Second level 340B pharmacy programs and program o Third level income

4 Click to edit Master text styles Second level o Third level

5 Gross Click income to edit earned Master text by the styles non-federal entity Second (RWHAP level recipient or subrecipient) that is o Third directly level generated by a supported activity or Fourth earned level as a result of the Federal award during the period of performance 45 CFR 75.2 PCN 15-03

6 Click to edit Master text styles Funds received by billing public or private health insurance for services provided to eligible RWHAP clients Second level Fees, o Third payments, level or reimbursement for the provision of a specific Fourth service, level such as patient care reimbursements received under Medicare, Medicaid, or Children s Health Insurance Program Charges imposed on clients for services, as required by RWHAP Parts A, B, and C legislation The difference between the third party reimbursement and the 340B drug purchase price

7 Click Program to edit income Master does text not styles include: Second Rebates: level return part of a payment (specific to ADAP); o Third level Credits: Fourth transactions level that offset or reduce expense items allocable to the Federal award; Discounts: deductions in cost advance of a payment; or interest earned on any of the above

8 Click For Parts to edit A, B, Master and C, text allowable styles costs are limited to: Second level Core o Third medical level services Support Fourth services level Clinical» quality Fifth level management (CQM) Administrative expenses (including planning & evaluation) as part of a comprehensive system of care for low-income individuals living with HIV

9 Click For Part to D, edit allowable Master text costs styles are limited to: Second level Family o Third centered level care involving outpatient or ambulatory care Support services CQM Administrative expenses for low-income women, infants, children and youth affected by or living with HIV

10 Click For Parts to edit F, allowable Master text costs styles are limited according Second level to the appropriate statutory provision, o Third level i.e. SPNS (Special Projects of National Fourth Significance), level AETC ( AIDS Education and Training Centers)

11 Click to edit Master text styles Support activities in excess of caps imposed by RWHAP: Second level Program o Third level income may be used to support activities Fourth in excess level of a cap that is imposed directly by» Fifth the level RWHAP, as such costs are allowable Examples include: administrative costs, CQM and indirect costs Frequently Asked Questions for Policy Clarification Notices and HRSA/HAB

12 Click to edit Master text styles! RWHAP Second recipient level and subrecipients may not o use Third award level funds or related program income Fourth to pay level the salary of an individual at a rate in excess of Executive Level II, currently at $185,100 as of 1/10/16. Frequently Asked Questions for Policy Clarification Notices and HRSA/HAB

13 Click to edit Master text styles To the extent available, recipients and subrecipients must disburse funds available from program income and Second rebates level (Part B) before requesting additional cash o payments Third level Program income for service provided within one period of performance may be received in the following period, and should be utilized in the year in which it is received Example: Fiscal year (FY16) ends June 30 th. Service delivered June 29 th. Program income received July 6 th, and should be spent in FY17

14 RWHAP Click to Parts edit A Master & B have text a styles one-year performance period Second level o Third level Implication:» Fifth Program level income must be disbursed within that same period of performance (one year)

15 RWHAP Click to Parts edit C, Master D & F text have styles multi-year performance periods. Second level o Third level Implication:» Fifth Program level income must be disbursed within that same period of performance (usually 3-5 years)

16 Click to edit Master text styles To the extent that it is available, program income must be spent first. Second level o Third level Recipients must include program income projections when planning for services based on the comprehensive HIV care and treatment needs of the recipient s service area Estimate (to the extent possible) how much program income will accrue Budget projections implications Strategic thinking about services and allocation

17 Additive: Click to added edit Master to funds text committed styles to the Second project level or program and used to further o Third eligible level project or program objectives Program income may only be used for allowable costs under the award

18 Click Recipients to edit are Master required text to styles track and account for all program income to demonstrate Second level that it is allowable and allocable o Third level Recipients Fourth must level report Federal program income» earned Fifth level on Line L of their Federal Financial Report (FFRs)and Federal program income expended in accordance with the addition alternative on line N Tracked per funding stream Implications for tracking system and accounting needs

19 Click to edit Master text styles Subrecipients should retain program income for Second additive level use within their own programs Recipients o Third level must monitor utilization to ensure allowable expenditures Program» income Fifth level earned by subrecipients must be reported to recipient Program income earned by the subrecipients should not be reported on the recipient s FFR

20 Can Click program to edit income Master text be used styles to pay for services that Medicaid does not cover? Second level o Third level Yes. Program income may be used to pay for any medically necessary services that Medicaid does not cover or only partially covers, as well as premiums, copays, and any deductibles otherwise allowable under RWHAP.

21 If an Click ADAP to purchases edit Master a client s text styles insurance, but the RWHAP Part C program purchases the medication Second and level bills the insurance, who generates program income? o Third level Answer: Part C. As they generate the program income by billing insurance, they would receive the program income

22 Click to edit Master text styles Second level o Third level

23 Permit Click covered to edit Master entities text to styles stretch scarce Second Federal level resources as far as possible, o Third reaching level more patients and providing Fourth more level comprehensive services

24 Opportunity Click to edit to Master provide text additional styles RWHAP Second services level and/or extend the reach o Third of existing level services to improve health outcomes for PLWH

25 Click to edit Master text styles Average savings of 25% - 50% on outpatient drug Second purchase level for 340B covered entities Savings may be used to: o Third level Reduce price of pharmaceuticals Expand services offered Provide services to more patients

26 Click to edit Master text styles 1. Physician/NP/PA writes script for Truvada 2. Patient takes script to the pharmacy Second level 3. Pharmacy orders Truvada from an approved 340B supplier o Third at level $500 and bills the patient s insurance 4. Insurance company reimburses the pharmacy $1, Pharmacy deducts the contractually agreed fees (e.g. $120) and passes the rest to the covered entity: $ Covered entity pays the manufacturer or distributor $500 for the Truvada 7. Covered entity keeps $480 as the 340B revenue and reinvests it to RWHAP

27 Click to edit Master text styles All 340B generated revenue is considered program income When Second the RWHAP level grant is the sole Federal award that makes o Third an organization level eligible as a 340B covered entity, all program Fourth income level should be attributed to the RWHAP grant When an entity is 340B eligible and purchases pharmaceuticals via 340B pricing under multiple awards, the recipient must use reasonable allocation method for the attribution of costs and program income, and be able to document the methodology used

28 Click Same to as edit other Master program text styles income, and must be used the same way Second level Reinvested o Third level in RWHAP Must be spent within certain time periods (depending on RWHAP part)

29 Click Opportunity to edit Master to expand text services styles Second Dental level o Third level Behavioral health Food pantry

30 Look Click at to the edit care Master continuum text styles in your jurisdiction or organization. Second level What o Third kind level of services would help increase retention in care? What kind of services would help increase viral suppression rates?

31 Click 340B program to edit Master income text should styles be included Second level in projections and budget tracking o Third level Best practices include developing a plan to spend down program income, as well as 340B program income so as not to have unobligated balances (UOB)

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