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News of an electronic medical record (EMR) conversion often brings about palpable anxiety and anticipation as a covered entity (CE) or health system braces itself for an enormous amount of change and new and improved avenues for patient care. These feelings ripple through every impacted department – particularly pharmacy – and the CE’s 340B program. There will be inevitable challenges during conversion; however, many of these can be mitigated with adequate preparation. Visante recommends several steps that can be taken in advance of and after the “go-live date” to ensure a more seamless transition relative to the 340B program:
Pre Go-Live:
- Notify all third-party administrator (TPA) vendor(s) of an upcoming EMR conversion and request the latest EMR data specification document(s) from the vendor(s) as soon as possible. Much time and planning are required to help mitigate any financial impacts to the CE during and beyond the transition period.
- Review the data specification document(s) to identify any newly available fields that would improve upon any current data files.
- Provide the data specification document(s) and any new requests for available fields to the CE’s identified IT resource as soon as possible. Report writing and/or modification can require considerable time and effort. Fine-tuning the test reports once the TPA has received them can also require additional time to ensure data accuracy.
Tip: Ensure that the IT resource understands the required naming convention for any test/production files received by the TPA. - Ensure that at least one individual with significant knowledge of 340B operations represents the program in all meetings and planning sessions related to pharmacy and the 340B program. This person’s input will be invaluable and contribute to a more efficient, less costly process. It will eliminate the need to revisit scenarios in which transitional plans would adversely impact the 340B program.
- Review and provide input/feedback on specific workflows related to 340B (e.g., update of primary NDCs in the EMR; order entry and process for exclusion of patient home medications, white-bagged items, or medications received as a result of manufacturer patient medication assistance programs; process for communication of new EMR and/or physical locations; addition of any state Medicaid- and CMS-required modifiers on 340B drug claims, etc.).
- Ensure any prior EMR reports required by the 340B program are replicated and accessible in the new EMR.
- Review wholesale acquisition cost (WAC) (if applicable), group purchasing organization (GPO), and 340B expenditure before conversion to establish a baseline for the current “normal” spend on each CE wholesaler account type.
- Review financial information relative to each entity-owned retail pharmacy and contract pharmacy PSA agreement to determine current “normal” drug expenditure and savings with the existing EMR data.
- Review current claims data volumes from the existing EMR reports in each affected TPA to establish a baseline of expected claims volume post-go-live with the new EMR.
- Obtain a list of each of the following:
- All EMR location codes and a description of each that will be used in the new EMR
- All patient encounter types used in the new EMR should also be classified as ‘inpatient’ or ‘outpatient.’
- All payer codes and a description of each new EMR will be the billing source; this list should also specify which payer codes and descriptions fall under in and out-of-state Medicaid if not evident.
- Create a new or update the current trial balance crosswalk with the latest EMR codes and the most recently filed Medicare Cost Report (MCR) and Working Trial Balances for Revenue and Expenses.
Tip: Retain the previous crosswalk with EMR codes from the old EMR for historical reference. - Determine the exact access necessary to view specific areas of the EMR for audit purposes. Examples include:
- UB-04s and/or CMS-1500s – as applicable
- Medication/Formulary lists and primary NDCs in the EMR
- Administered medication dates/times and bedside scanning data
- Dispense dates/times (if charge methodology is ‘Charge on Dispense’)
- Patient Status at the time of administration/dispense – as applicable
- Prescriber orders
- Additional required documentation found elsewhere in the EMR (e.g., Visit Notes, Discharge Summaries, Nursing Flowsheets and Assessments, Referrals, Scanned Documents, etc.)
- Complete training for the new EMR before the ‘cut over’ date (transition date from the old EMR to the new EMR) to ensure seamless data access.
Tip: Be proactive. Many organizations have a “no training, no access” policy. - Understand the ‘cutover’ process, timing, and potential impact on 340B qualifications and/or data feeds and files.
- For auditing purposes, know the exact date on which end-users will no longer retain access to the prior EMR.
- Update all TPA applications to recognize new location codes, patient statuses, payers, etc.
- Work with each affected TPA to determine timelines and testing procedures for the new data.
- Review each TPA application’s test files (e.g., patient encounters, prescribers, eRx files, utilization files, referrals, etc.).
- Update Policies and Procedures and Standard Operating Procedures as needed.
Tip: Some or all of these documents may include screenshots or other references to the current EMR and will need to be modified to reflect new practices.
Post Go-Live:
- Review claims data volumes from the new EMR reports in each affected TPA to determine if the count(s) are similar to pre-go-live claims data volumes.
- Review data error reports from each affected TPA to identify potential issues quickly.
- Review WAC (if applicable), GPO, and 340B expenditure post-conversion to identify whether this data aligns with or demonstrates improvement compared to spending prior to the EMR transition.
- Review financial information relative to each entity-owned retail pharmacy and contract pharmacy PSA agreement to determine if new drug expenditure and savings data align with or have improved compared to the previous EMR data.
Proactive work and discussions can prove highly productive and avoid potential unnecessary stress and anxiety. Visante can assist CEs with EMR conversions relative to the 340B program. Please reach out to us for more information!
Sara Rainey is 340B Program Director, Hospital & Health Systems Services at Visante. She can be reached at srainey@visanteinc.com
