Category: General
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In the complex landscape of healthcare, compliance with the Health Resources and Services Administration’s (HRSA) 340B program is paramount for covered entities. As organizations strive to optimize their participation in the program, one critical aspect is preparing for HRSA audits. To shed light on this crucial process, we turn to Kristin Andolfo, a seasoned expert in navigating HRSA audits. Kristin is a 340B ACE Senior Consulting Advisor at The Craneware Group.
With over 300 HRSA audits under its belt, along with extensive experience in handling manufacturer, state, and external audits, The Craneware Group is uniquely positioned to offer valuable insights on how covered entities can effectively prepare for HRSA audits. See our step by step below guide below:
1. Alert and Gather All Key Players
The first step in preparing for a HRSA audit is to ensure that all relevant stakeholders within the organization are informed and engaged. This includes representatives from pharmacy, finance, compliance, and any
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As we welcome the fresh energy of spring, now is the perfect time for 340B covered entities to conduct a thorough review and update of their 340B program. Ensuring your program’s compliance and efficiency is akin to spring cleaning—tidying up, organizing, and preparing for the year ahead. Below, we outline essential steps and checks to maintain the excellence of your 340B program as we transition to this new season.
1. Review Your State’s Medicaid Website for New BIN/PCN/Group Updates
It’s essential to regularly check the Medicaid website for your carve-in states, looking for any updates related to Billing Identifier Number (BIN), Processor Control Number (PCN), and group numbers. These details are crucial for accurately processing pharmacy claims and securing appropriate 340B discounts. Often, at the beginning of the year, Medicaid agencies will update their websites with the latest BIN/PCN/Group numbers based on recent contracting information with Medicaid Managed Care organizations.
2. Fiscal Year-End Specific Checks
For
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On February 2, six senators known as the “Gang of Six” – John Thune, Debbie Stabenow, Shelley Moore Capito, Tammy Baldwin, Jerry Moran and Ben Cardin – unveiled a discussion draft bill intended to preserve the 340B program and codify in statute many of its operational provisions. The draft bill, titled Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of 340B Act (SUSTAIN 340B Act or SUSTAIN Act), was accompanied by an explanatory statement and request for information (RFI), with many questions for Covered Entities (CEs) to review and provide further responses to the Gang of Six.
Stakeholders were asked to review the RFI and provide additional responses, with comments due by April 1. As we approach the deadline for comments, it’s crucial to delve into the most critical elements of the bill and discuss next steps for 340B stakeholders.
340B’s Purpose (Section 2)
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With so many challenges facing health systems today — from 340B contract pharmacy restrictions to drug shortages, labor issues, and ever-rising costs — revenue integrity has become essential to financial stability.
With huge increases in drug expenditures from pre-pandemic levels, health systems must focus on maximizing efficiency, reducing medication costs, and increasing revenue. In this new reality, hospital pharmacies should think and act like a business unit, not just a cost center. Yet many hospitals unknowingly receive reimbursements that fall short of their medication costs, leading to financial strain and plenty of stress and anxiety for hospital and pharmacy administrators.
In healthcare, revenue integrity refers to the comprehensive approach organizations take to ensure accurate billing, appropriate reimbursement, and proper and efficient utilization of resources. For some hospitals, it represents a new way of doing business. If there are gaps and silos in their processes, it’s hard to achieve optimal medication revenue cycle performance.
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