Since 2019, ProxsysRx’s 340B team has generated over $500 million in 340B revenue for the health systems we serve. During that time, we’ve developed any number of strategies and tactics for overcoming 340B ESP and other manufacturer restrictions. Below are the seven key elements of our process.
1. Establishing communications between health system providers and their outpatient pharmacies.
With manufacturer restrictions, it’s more important than ever that health systems have onsite pharmacies partnering with them to capture as many 340B-eligible prescriptions as possible.
ProxsysRx manages and/or owns retail outpatient pharmacies located on hospital campuses nationwide. Our pharmacists routinely make themselves available to system physicians and providers — helping them determine the best 340B-eligible medications for patients in need. Our 340B Support team is also available to help guide clinical-practice decisions for hospitals whose 340B programs we manage.
2. Uploading only the 340B Data required, and NO MORE.
When working in the 340B ESP platform, you should never upload any data that isn’t absolutely required by the platform. We submit the NDCs only from manufacturers that impose 340B pricing restrictions that are contingent on data reporting.
3. Never trusting 340B ESP to restore prices on its promised scheduling.
340B ESP says health systems should expect a period of 10 days, post-submission, for 340B prices to be restored in their contract pharmacies’ 340B wholesaler accounts. In reality, that rarely ever happens within 10 days — if at all.
Which is why ProxsysRx has implemented a system for checking all NDCs, in all of our health systems contract pharmacies’ 340B accounts, before instructing their TPAs to restart processing on any restricted NDCs. There are more than 1400 restricted NDCs, and for every contract pharmacy a covered entity has, each and every one of those 1400 NDCs must be checked. Needless to say, it’s a process that would be impossible without proprietary software to do just that.
4. Never trusting 340B ESP price restoration, period.
When dealing with 340B ESP, we’ve learned that health systems cannot assume that any 340B price restorations they have will actually be honored. Manufacturers working with 340B ESP routinely, and unilaterally, decide that the purchases made for arbitrarily-selected contract pharmacies are more than the dispenses.
5. Not assuming that submitted eligible dispenses result in 340B price access.
Some manufacturers now require you to submit 340B purchase data reports within 45 or 60 days from dispense — or they disallow those submissions. Although ProxsysRx mines clients’ 340B-submission records for eligible prescriptions missed by their TPAs, the time frame is tight with these manufacturer requirements.
6. Modifying your TPAs’ reports to be compatible with 340B ESP.
If you’re thinking you can simply pull reports from your TPAs and upload them, when submitting your own reporting to 340B ESP, think again. Most TPAs’ reports require significant modifications first. Your own uploads have to be submitted in 340B ESP’s exactingly-specified format, and every upload has the potential for reporting errors that can cause failures.
7. Ignoring 340B ESP’s alleged “support” service.
Nobody working with 340B ESP — or the manufacturers — has ever helped our team when our clients didn’t receive the 340B prices to which they’re entitled, even when months have passed since we made data submission.
ProxsysRx is here to help, if you have questions.
There are so many ways to optimize your 340B drug program savings and benefits. For more information, contact Howard Hall. C: 214.808.2700 | firstname.lastname@example.org