As we noted in a previous post, 340B ESP is nothing less than a brazen and (in our opinion) unlawful ploy by the drug manufacturers to evade the discounts they are legally obligated to offer eligible entities — by placing extraordinary, and unnecessary, reporting burdens on hospitals submitting claims for 340B savings.
That said, until Congress and/or the courts step-up and give HRSA the legal authority it should have to enforce the regulations established by Congress in 1992, eligible entities seeking to maximize 340B savings and revenue will continue being, for all practical purposes, strong-armed into reporting a significant percentage of their eligible prescriptions through the 340B ESP website.
Below are six of the most common errors made by entities in reporting 340B-eligible prescriptions — and our advice for avoiding them.
1. Uploading Excessive 340B Data
Never upload more data than is absolutely necessary, and required, by 340B ESP. We understand just how difficult it is to determine the necessary minimum — particularly given how difficult it is to find a comprehensive list of impacted National Drug Codes (NDCs) required for reporting inclusion. ProxsysRx has developed a dependable process for scrubbing reports, from the TPAs working with the health systems we serve, before submission.
2. Trusting 340B ESP to Restore Prices On Its Promised Scheduling
Don’t ever assume that 340B prices are restored in your contract pharmacies’ 340B wholesaler accounts by the 10-day post-submission mark (the time frame 340B ESP says to allow).
It’s critical that you check all NDCs, in all of your contract pharmacies’ 340B accounts, before instructing your TPAs to restart processing on any restricted NDCs. When notice of NDC restrictions was introduced, TPAs began blocking processing — since there are times when Wholesale Acquisition Costs (WACs) are loaded, instead of 340B pricing, which leads to covered entities overpaying.
There are more than 1300 NDCs (identifier codes for drugs used by FDA), and every NDC must be checked for each and every contract pharmacy a covered entity has.
3. Trusting 340B ESP Price Restoration, Period
When dealing with 340B ESP, never assume that any 340B price restoration you have will actually be honored. If any manufacturer working with 340B ESP decides, unilaterally, that the purchases made for any of your contract pharmacies are more than the dispenses, they’ll refuse to pay the wholesaler’s chargeback. Which will result in a credit-rebill — which results in you, the covered entity, paying WAC — which is a much higher price.
4. Assuming submitted eligible dispenses result in 340B price access
Eligible 340B dispenses often do not occur in full-package-size increments. It may take months, and multiple claims, to equal a full reorderable package size. But some manufacturers will not allow 340B purchases past 45 or 60 days from dispense. Which means covered entities will likely never be able to get many of the 340B prices they are entitled to.
Although we mine for eligible prescriptions missed by the TPAs, the time frame is tight with these arbitrary, fraudulent manufacturer requirements.
5. Counting-On 340B ESP-Compatibility In Your TPAs’ Reports
When you submit your own reporting to 340B ESP, you can’t simply pull reports from your TPAs and upload them. Not without making significant modifications. Your uploads must be submitted in a highly-specified format, and every upload is fraught with potential pitfalls that can cause failures.
6. Counting-On Support From 340B ESP
At the very top of the 340B ESP home page, you’ll find an email address — email@example.com. Don’t waste your time.
In our experience, nobody working with 340B ESP — or the manufacturers — will help you when you don’t receive the 340B prices to which you’re entitled, even if months have passed since your first data submission.
Some TPAs’ systems are impossible to pull submission-data from, because their systems require 340B prices to be available before they’ll even consider dispenses for matching. The absence of 340B pricing means reports from those TPAs will not produce data you can submit.
It’s a circular, chicken-or-egg, conversation: No price equals no data. Which equals no price. Which ultimately adds-up to No Excuse for what 340B ESP and the manufacturers are doing to the 340B law, as well as the entities it was created to serve.
The good news about 340B ESP, for covered entities
Despite the well-founded outrage over 340B ESP and manufacturer restrictions, ProxsysRx continues to generate significant savings and revenues for the health systems we serve. Altogether, our efforts have generated tens of millions in 340B savings and revenue for the hospitals we serve.
ProxsysRx is here to help, if you have questions.
There are so many ways to optimize your 340B drug program savings and benefits, while minimizing the likelihood of noncompliance. For more information, contact Howard Hall. C: 205.588.0946 | firstname.lastname@example.org