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Whether it’s new manufacturer restrictions affecting script and data qualification, amended state laws or regulations, or updated audit guidelines, the 340B landscape is constantly evolving. So, it’s no surprise that managing an organization’s 340B program is not easy to tackle alone, even for experienced policy veterans. For covered entities, leveraging the knowledge, skills, and experience of the right 340B solutions partners can lead to increased cost savings, enhanced patient reach, and compliance peace of mind.
Unfortunately, not all 340B partners are the right fit for each covered entity (CE), and utilizing the wrong partner can be financially costly, reduce the total cost savings captured, and potentially leave your program open to audit findings. That’s why, no matter whether you’re evaluating a current vendor or looking for a new 340B partner, it’s essential to keep an eye out for the following warning signs:
1. Vague or non-transparent fee models: Let’s face it, leveraging the expertise of an outside 340B partner costs money. That’s why it’s essential to negotiate a fee structure that’s financially responsible and provides the necessary services to capitalize the 340B program before kicking off the partnership. Pay attention to how the partner calculates fees. Is it by script volume or per script? Are there additional fees that aren’t being considered? Does the fee incorporate audit preparedness and readiness?
Covered entities should look for a partner that understands their mission, provides services that simplify operations, and helps them reach their goals. Just because a 340B partner is the most affordable doesn’t mean it’s the best fit for an entity’s mission.
Bonus tip: When it comes to partnership agreements, read the fine print. Some covered entities can fall into exclusivity contracts that are difficult to break. Your selected vendor should be a true partner, not a burden.
2. Lack of clear compliance support or audit readiness: There are two realities that won’t be changing anytime soon—that covered entities participating in the 340B program are bound by strict (and evolving) federal guidelines and requirements, and that 340B HRSA audits can be nerve-wracking.
However, finding the right 340B solutions partner can help alleviate your 340B nerves and earn your organization a compliance gold star. Ask potential 340B vendors what audit services and/or support they offer and the steps they take to ensure compliance. The right 340B solutions vendor will ensure their CE partner is data compliant before an audit takes place and will work with the entity to advise on any potential risks.
Bonus tip: Find out if your 340B partner is prepared to support your organization during a live HRSA audit.
3. Limited or no customization for your organization’s size or mission: There are multiple types of covered entities receiving 340B funding, including disproportionate share hospitals, federally qualified health centers, and grantees. Each of these has a distinct set of federal requirements. Therefore, it’s crucial to find a 340B partner with a proven track record of successfully empowering your organization’s specific 340B use case.
What’s more, the changing face of 340B and the dynamic needs of underserved patients mean that every CE—even those within the same category—has different requirements. If your 340B program has been successful and is prepared to grow, your 340B partner should be ready with guidance. If your CE is ready to change its scope or update its mission, your 340B partner should be on point to accommodate that process.
Bonus tip: Manufacturer restrictions are unlikely to disappear anytime soon. Prioritize finding a 340B partner that understands what the current restrictions mean for your organization and can navigate future limitations in an agile manner.
4. Poor Communication: It can be easy to translate the 340B program into just numbers, dollars, and data. But at heart, it’s about expanding relationships between care providers and underserved patients and improving healthcare outcomes.
Maybe this feels obvious, but communication is a two-way street. That means it’s imperative to find a partner that will truly listen to your 340B strategy questions and concerns, and then provide timely answers and updates.
Bonus tip: If a CE informs their 340B solutions vendor that they’re about to go through a HRSA audit and receives a tepid response, that’s a red flag. When your organization is facing questions about qualifications, cost savings, or data audits, your 340B partner should be jumping in to help, regardless of the size of your program.
Now that you’re up to speed on what you don’t want from a 340B partner, let’s briefly review how to find one that fits your organization like a glove. Conferences are often great venues to source potential partners, and the more specific the conference, the better. There are numerous conferences and healthcare symposiums that bring covered entities and 340B solutions vendors together. Vendor referrals from other covered entities can be worth their weight in gold, especially when the referral source has a similar use case and/or is located in the same state. Finally, new and existing covered entities can benefit from the latest 340B news and thought leadership. While it can be a drag to filter through the already crowded news space to find updates on the 340B world, savvy industry stakeholders maintain a carefully curated list of online resources that provide vital information and 340B news.
To learn more about how Avita Care Solutions is committed to promoting health equities by providing an integrated suite of comprehensive, compassionate, and inclusive health care and pharmacy services to underserved communities, reach out to us today.
Brett Davis is 340B director of program integrity at Avita Care Solutions. He can be reached at brett.davis@avitacaresolutions.com
