Getting started with the 340B Program
The first step in preparing your health system for enrollment in the 340B program is to ensure that you’re eligible to participate. If your hospital isn’t already registered, you might want to refer to our previous blog post, Are you ready to enroll in the 340B program?
Why 340B programs should be optimized, not maximized
We recommend a policy of optimizing 340B savings that’s both aggressive and conservative. Which is to say that you should aggressively pursue 340B savings for every prescription that’s worth pursuing; after all, some prescriptions are simply too low-cost, at market rates, to justify the effort needed to generate nominal savings.
Ideally optimized 340B programs generate a net savings on every eligible prescription claimed.
At the same time, optimized 340B programs, by necessity, utilize proprietary software that keeps detailed electronic records on every prescription that hospitals’ outpatient pharmacies (and contract pharmacies) fill, enabling covered entities to instantly produce all the evidence they’ll ever need to respond to audit requests.
Elements of optimized 340B programs
An unblemished record of performance
Yes, it sounds obvious, but it’s still worth mentioning: Whether 340B programs are managed entirely in-house, or they use outsource partners for support, they need to be sure the people involved have the skillset — and, ideally, the track record — to ensure compliance at all times. Since 2013, ProxsysRx has optimized dozens of 340B programs, and not once has a hospital we serve ever been fined for a 340B violation.
The ability to mine records for 340B-eligible prescriptions: Present and Past.
ProxsysRx’s proprietary software not only identifies current and past reimbursable prescriptions for our new clients, it automatically applies for those reimbursements. Typically, we’ll mine new clients’ prescription histories dating back as much as a full year prior to our start date with them.
Establishing easy-to-follow Best Practices for your prescribers
In our experience, insufficient knowledge of best practices is the most common reason prescribers don’t take full advantage of their 340B programs. Which is why a clearly-defined policy is critical to optimizing your program. ProxsysRx’s software also identifies prescribers in our clients’ systems who aren’t taking full advantage of 340B savings and revenue.
Very often, the solution is simply familiarizing providers with the prescribing procedures needed to ensure eligibility. Occasionally, prescriptions being rejected is simply a matter of matching elements in prescription forms. IE: A name entered Bob in one place and Robert in another will result in denial. Our system catches and corrects those errors.
Establishing best practices for COVID-19
If you haven’t already, you should carefully consider how your 340B policies and procedures align with the current public health emergency.
Here are some Covid-related steps you’ll want to take to optimize your 340B program:
- Evaluate your record-keeping practices for patient eligibility in light of your emergency procedures. For instance, if you temporarily switch to a doctor-only match, can your program maintain compliance requirements?
- Ensure your 340B policies and procedures accurately reflect your current telemedicine practices.
- Review your Group Purchasing Organization (GPO) purchasing practices. GPOs are now allowed to purchase drugs in short supply.
- Enroll in the COVID-19 Uninsured Program. Health and Human Services now provides reimbursement at Medicare rates for COVID treatment testing and treating for uninsured COVID-19 patients.
Supplementing your 340B software with manual claims qualification
It’s likely you have a subset of 340B-eligible claims that fall outside of standard workflows. Typical examples of those claims include:
- Referral-based claims requiring additional documentation
- Scripts requiring preauthorization
- Claims for infusions with multiple formulations
- Specialty-drug claims outside of your standard date-written windows
Hospitals partnering with TPAs in their 340B programs should never hesitate to ask them for assistance identifying these claims — then holding those claims for manual review and validation. If these claims meet qualification requirements, you‘re still eligible for 340B savings — provided you complete the additional documentation and approval steps required.
Optimizing your contract pharmacy 340B savings
Contract pharmacies play a critical role in optimizing the potential savings and revenue that eligible hospitals can generate with well-managed 340B programs. They’re also an important extension of a 340B hospital’s overall care of, and for, its outpatients.
For an in-depth review of how to optimize your contract pharmacy 340B savings, please refer to our previous blog post on the topic.
Reviewing the 340B eligibility of high-cost specialty drugs
High-value specialty prescriptions often have unique prescribing workflows which can lead to significant reductions in 340B savings. In situations where the likelihood of eligibility is high, you should consider a strategy for accelerating both your automated and manual qualification processes.
Keeping current with 340B pricing in wholesaler catalogs
Wholesale pricing is a constantly-moving target, and difficult to track. Pricing inaccuracies are often due simple to wholesaler catalog error. Which is why it’s so important to maintain current and accurate catalog pricing with your wholesaler(s).
ProxsysRx is here to help, if you have questions.
These are just a few of the ways 340B drug programs can be savings. For more information on the full range of steps you can take (including, for instance, aligning your best practices for telehealth), contact Howard Hall. C: 214.808.2700 | howard.hall@proxsysrx.com
