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W. Edwards Deming is a renowned statistician and expert in quality management. He is often quoted as saying, “Uncontrolled variation is the enemy of quality.” In the realm of 340B, including 340B contract pharmacies, that change is both continual and constant. Change, or uncontrolled variation, can significantly affect the quality of a 340B contract pharmacy program. However, through strategic initiatives, covered entities (CEs) can effectively navigate these external factors to support their contract pharmacy relationships.
As a first step, it is important to recognize and comprehend the key elements at play in the evolving landscape of 340B contract pharmacies. This understanding can enable covered entities to perform an analysis of the current state of their own 340B contract pharmacy relationships.
Key Elements of the Evolving Landscape:
- Identifying the 39 pharmaceutical manufacturers that have a restriction policy for 340B contract pharmacies
- Reviewing each manufacturer’s policy
- Understanding any state-specific restrictions
- Registering with the 340B ESP platform and understanding its role with 340B contract pharmacy
- Partnering with your 340B third-party administrators (TPAs)
What’s Next?
Once you’ve conducted a comprehensive analysis of the current state of your contract pharmacy relationships, you’re ready to develop a structured approach to planning for the future.
I’d love to share some strategies that the 340B team here at CPS have explored with covered entities of various sizes and designations. Click here to see those additional insights.
Assigning resources to actively manage your 340B ESP participation and continuously monitor contract pharmacy performance is crucial—and CPS can help. By understanding the current state assessment, we can develop and execute a strategic action plan for your 340B contract pharmacy program with an emphasis on compliance. Importantly, our experts always stay abreast of changes in the industry, allowing us to pivot our actions accordingly and promote an effective long-term strategy for your CE.
Dennis Killian, senior director of 340B Solutions at CPS, can be reached at Dennis.Killian@cps.com.
