Prisons struggling with the high cost of treating inmates with viral illnesses such as hepatitis C and HIV can turn to the 340B program for relief, but participation is often tricky.
That was the takeaway of “Demystifying 340B for Correctional Institutions” a webinar conducted Wednesday by the National Hepatitis Corrections Network and the National Virus Hepatitis Roundtable. Panelists included medical and pharmacy officials from corrections systems in Alaska, Minnesota, and Rhode Island. Jeff Davis, of counsel with the law firm of Baker Donelson in Washington, D.C., illustrated how the 340B program worked within correctional institutions.
Dr. Robert Lawrence, chief medical officer for Alaska’s corrections system, observed that even though correctional institutions are responsible for inmates’ health care, they “are not set up primarily as healthcare institutions.” The prevalence of prisoners with hepatitis C in some institutions, he said, can exceed 40 percent. While the disease can often be successfully treated with oral medication, such a regimen can run from the mid to high five-figures.
Correctional institutions have found that by contracting with a 340B covered entity to treat inmates, or by enrolling as a 340B entity, they can maximize their available funds and improve inmate care, panelists said.
According to Davis, prisons and jails typically participate in 340B in two ways: in partnership with a hospital, or by becoming an STD/Section 318 clinic subgrantee.
Partnering with a hospital can be easier for correctional facilities, because as the 340B covered entity in the arrangement, the hospital, not the facility, is ultimately responsible for compliance with 340B program requirements. The hospital and the institution must ensure that inmates meet the 340B program definition of patient. An advantage of the hospital partnership model is that correctional institutions can access 340B pricing on more types of drugs. As an STD/Section 318 clinic subgrantee, there is less question about whether an inmate meets the 340B patient definition.
Lawrence noted that many of Alaska’s correctional facilities took the STD/Section 318 clinic subgrantee route, but primarily because they already had close relationships with local public health and STD providers, many of which were already providing in-kind support to prison healthcare delivery.
“You need to work on those relationships, and make sure it’s in lockstep together,” he said.
Pauline Marcussen, administrator of healthcare services for Rhode Island’s correctional system—which Lawrence hailed as a 340B success story—confirmed that a close relationship with local health authorities is necessary for smooth functioning as an STD subgrantee.
Every new prisoner in Rhode Island is screened for the possibility they may need pharmaceutical treatment for hepatitis C or HIV, with STD tests provided in-kind from the state health department.
But Rhode Island is still only obtaining drugs through 340B to treat hepatitis C and HIV. It is inquiring whether it may also do so to treat diabetes.
Daily management issues must also be considered. “One of the unique challenges we face is the tracking of every single script and every unit dose card that comes in…it’s a matter of tracking every dose that is left on the card,” Marcussen said, adding that the issue was compounded whenever a prisoner was transferred to another institution. In a larger institution, it can be a daunting challenge for the 340B coordinator.
Brandon Sis, a senior pharmacist for corrections with MMCAP Infuse, a group purchasing organization for government facilities that provide healthcare services, advocated a very deliberate approach to avoid facing a tough audit or other issues.
“Start low and go slow,” he said. “If you’re starting off with a handful of medications or disease states that are really kind of closely tied to the eligibility criteria, I think that’s going to be a lot easier to get up and running as opposed to going full jolt on it.”