340B Aware and Beware

Transcription

1 340B Aware and Beware Being aware of the complex and ever-changing 340B Drug Pricing Program rule help covered entitie maintain integrity and drive program value. Succeful 340B program focu on three fundamental objective; enuring compliance, optimizing aving and controlling kyrocketing cot of pharmaceutical. It a three-legged tool analogy, where all of the leg mut be in balance in order to tand olidly over time. To effectively navigate the complex dynamic of the 340B Program and addre challenge a they arie, it i important to elect the right partner a partner who truly undertand all of the nuance of thi complicated program. 1 Controlling Cot Covered entitie that own a pharmacy() which erve both inpatient and outpatient, bear the important burden of enuring that drug are purchaed on the correct account - wholeale acquiition cot ( WAC ), group purchaing organization ( GPO ) and 340B. And, importantly, that they mut enure that HRSA GPO Excluion rule i not violated. To ait in thi important cot and compliance iue, many covered entitie turn to plit-billing vendor to ait them. Mot plit-billing vendor will boat that they can alo eaily manage a contract pharmacy network, and often eek the excluive right to do o. Nothing could be further from the truth. It i important for a covered entity to be aware of the ditinction between thee two eential, but very different line of ervice. Split-billing olution allow the covered entity to eparate 340B eligible precription from non-340b eligible precription after the precription are dipened. The plit-billing olution attempt to do thi by gathering information on all patient charge from the covered entity information ytem. It ue thi information to enure that inventory for the internal pharmacy() i purchaed on the appropriate account. The ability to lower the overall cot of pharmaceutical purchae while remaining compliant i the goal, and the program performance i only a good a the quality and accuracy of the data. Thi mean the plitbilling olution mut work eamlely in the covered entity information environment. Chooing a plit-billing vendor i not a deciion to be taken lightly. By chooing the right plitbilling olution, a covered entity can be reaured that the overall cot of pharmaceutical it purchae i being optimized, 340B Program integrity i being maintained and diverion prevented. In addition, pharmacy peronnel are freed to focu on patient care.

2 2 Optimizing Program Saving Optimizing 340B Program aving through a contract pharmacy network i a win-win-win trategy for the covered entity, it patient and the pharmacie. For the covered entity, a contract pharmacy network enable it to capture an increaed number of precription written by it provider to it outpatient thu generating increaed 340B aving. Patient receive increaed acce to pharmacy care, and pharmacie enjoy a cloer relationhip with the covered entity and higher dipening fee. In addition, a contract pharmacy network enable covered entitie to contruct a more efficient program for it uninured patient. Contract pharmacy network provide the opportunity for covered entitie to achieve HRSA tated intent for the 340B Program to tretch carce Federal reource a far a poible, reaching more eligible patient and providing more comprehenive ervice. For covered entitie, the 340B Drug Pricing Program facilitate the extenion and expanion of ervice to the mot vulnerable and needy patient, thereby improving patient health and ultimately lowering healthcare expenditure. Etablihing an optimized contract pharmacy network, require a 340B adminitrator focued on all apect of the program. An adminitrator who undertand that each covered entity i unique and require a cutom olution. The 340B adminitrator mut tart with enuring the proper regitration of all clinic and pharmacie. From there it mut obtain all data feed in whatever format the covered entity can provide. Next it mut analyze the data to identify the key community retail pharmacie and pecialty pharmacie, where patient are filling their precription. Then it mut build the contract pharmacy network that optimize the capture rate of 340B eligible precription. Finally, it mut continually work with the covered entity to enure that every apect of the program i being optimized. A ucceful contract pharmacy network hould provide the following. High performing retail and pecialty pharmacie A cutomized trategy to contract with limited and excluive pecialty pharmacy network Thi will help enure that pecialty precription previouly locked out of a 340B program by health plan PBM and their captive pecialty pharmacie can be captured in the program Dedicated and engaged cutomer ervice, focued on optimizing the program Completely tranparent, real-time program reporting and analyi Including the ability to monitor and elf-audit every precription Pricing that i both tranparent and completely aligned with the covered entity There i lot of confuion in the market regarding program cot veru program value. Many 340B adminitrator will promote a per claim, per click or per pharmacy program fee tructure. Be aware of the many hidden fixed fee aociated with thee approache. In many of thee arrangement the program aving may not exceed the fixed fee

3 requirement, leaving the covered entitie 340B program at a financial lo. A ucceful 340B adminitrator hould be willing to provide a pricing methodology that align with the ucce of the program and put the 340B adminitrator fee at rik, baed on overall program performance. It a imple, tranparent and aligned approach if you think about it. So while many if not all of the plit-billing oftware companie offer to provide a contract pharmacy component a an add-on to their primary offering, keep in mind that thee are two very important albeit very ditinct program offering. Each with different requirement which provide different value propoition for the covered entity that hould never be part of a ingle buying deciion. Covered entitie need to maximize cot reduction and optimize revenue opportunitie. 3 Compliance What doe a covered entity need to be aware of when it come to HRSA audit? Since 2012, the number of covered entitie audited by HRSA ha increaed each year. Covered entitie that have never been audited before may receive notice in the near future notifying them of an impending audit. Legal expert have warned it i not a matter of if but when a covered entity may be choen to undergo an audit. Prioritizing the 3 fundamental 340B element will lead you toward a 340B program manager that offer the mot comprehenive ervice available. Enuring the highet level of program integrity and optimizing the amount of 340B aving generated. Over 75% of the audit conducted by HRSA have reulted in negative finding, with over 43 % identifying two or more dicoverie. Over half HRSA audit have reulted in the covered entity incurring penaltie, potentially requiring repayment to manufacturer. So far thi year, 28 covered entitie have undergone HRSA audit, with even entitie required to repay manufacturer due to diverion or duplicate dicount. Four entitie were terminated from the program for working with contract pharmacie without written contract in place. Thi i why it imperative for a covered entity to chooe a 340B adminitrator who urpae the current indutry tandard in the ability to enure program integrity and compliance. Subject to the rule of participation. covered entitie are allowed to provide 340B drug only to thoe individual who are patient of the covered entity. Currently, with the lack of pecificity in regard to the criteria defining eligibility, covered entitie mut be aware of and beware of providing 340B precription to individual who do not meet the program requirement. 340B adminitrator who are capable of providing covered entitie with the tool needed to have real-time acce to eligible precription a well a potentially eligible precription offer program optimization a well a elf-auditing capabilitie in today environment. According to the tatute, when an eligible entity voluntarily decide to enroll in the 340B program, it accept reponibility for enuring compliance with all proviion of the 340B program, including all aociated cot. Beware of 340B adminitrator that guarantee

4 100% compliance: check their hitory of audit occurrence and outcome. Only a killed 340B adminitrator, with a ucceful track record in navigating the ever-changing challenge of the 340B program can uccefully guide you through the complex and highly regulated, evolving federal drug dicount program. Prioritizing the three fundamental 340B element will lead you toward a 340B adminitrator that offer the mot comprehenive ervice available enuring the highet level of program integrity and optimizing the amount of 340B aving generated. When it come to participation in the 340B Drug Program ome word of advice. Be aware and beware.

5 About the Author Jame R. Love Chief Executive Officer, Wellpartner Jim Love joined Wellpartner a Preident in December 2011 and wa named Chief Executive Officer in April Prior to joining Wellpartner, Mr. Love had ignificant healthcare experience in both operation and invetment banking. He pent the early part of hi career in the invetment banking diviion of Merrill Lynch & Company where he led the healthcare group and provided both trategic and financing advice to a wide range of companie including Johnon & Johnon, Hopital Corporation of America, Medco, and Biogen Idec. Mr. Love left Merrill Lynch to erve a Executive Vice Preident of Synetic Inc. (and it ucceor company Medical Manager, Inc.) a publically traded healthcare information technology company, where he wa reponible for all finance and adminitrative function. During hi tenure at Synetic, Mr. Love led the effort to raie both debt and equity capital, acquire everal buinee, and ultimately merge the company with WebMD. After the merger with WebMD, Mr. Love returned to the invetment banking buine, at the Bank of Montreal, where he rebuilt the firm commercial and invetment banking healthcare effort, and at Madion William and Company, where he wa a enior invetment banker. Mr. Love received an A.B. degree from Brown Univerity, and a M.B.A degree from New York Univerity. Wellpartner: Who We Are A your trategic partner, we re committed to providing a complete 340B ervice uite that create value, and get it right. Wellpartner i the authority in 340B program management offering innovative technology and the broadet et of 340B ervice. By taying ahead of indutry change, Wellpartner provide a eamle, eay-to-ue olution for covered entitie currently or conidering participating in the 340B Drug Program. Our experience i your advantage. Our procee are finely-tuned toward achieving the bet reult for our cutomer, whether it i contracting, providing our URAC-accredited pecialty pharmacy ervice, enuring program compliance, aligning pecialty network acce, maximizing claim capture, or driving program value. Wellpartner i focued on excelling at thee tak, ince we hare the ame goal a our covered entity cutomer to preerve reource, in order to erve thoe who need it mot. Wellpartner When it matter mot Copyright Wellpartner All right reerved. Thi material or any portion thereof may not be reproduced or ued in any manner whatoever without the expre written permiion of the publiher.