Spring Cleaning: Three Priorities for Tending to Your 340B Program

SPONSORED CONTENT by Madeline Wallack

A highly contagious novel virus, unprecedented demands on providers, new federal programs and funding, losses on preventative care and elective surgeries, and crazy supply shortages. To say that the last year has been overwhelming on 340B entities is a serious understatement.

Like any phase in life where the objective is survival, program maintenance and “busy work” falls by the wayside.  Unfortunately, 340B is a high-maintenance program and it is time to clear off the desk and get to work. You may have transaction testing or OPAIS registrations to handle but wondering what else needs to be done to ensure you are on top of the latest audit trends.

Luckily, we at Rx|X have developed a prioritized list of areas of focus just in time for Spring Cleaning!

  1. Developing an SOP on Responding to Manufacturer Good Faith Inquiries:  With the recent influx of inquiries, you may find yourself dealing with each as a “one-off” instead of having a strategy and chain of command. Rx|X works with its clients on establishing best practices for responses, including guardrails for when it starts to cross the line into an audit.
  1. Re-evaluating your Self-Audit Workplan: Has it been a while since you really examined the value of your monitoring strategy? After years of focusing on transaction testing, we are seeing a shift toward data reviews with a focus on procurement practices. Testing is still important, but if you are inefficient or not finding any issues but ignoring Medicaid claims review, you may need to step back and ensure that your staff’s time is used wisely. If you are wondering about a resource to identify gaps, we recommend comparing your audit workplan to the FY2021 HRSA Data Request List as a great starting point.
  1. Documentation Roundup (perfect for a summer intern or resident on admin rotation!) We recommend:
    • assembling all contract pharmacy agreements, including identifying which have the most current language and list of pharmacies, highlighting the key sections that auditors look at, and organizing in its electronic folder 
    • checking OPAIS vs contracts and registrations for any address or name discrepancies
    • For hospitals, reviewing the accuracy of the Medicare Cost Report versus OPAIS to avoid findings on incorrect data.

For any questions, please do not hesitate to reach out to us. Happy Spring!

Madeline Wallack is co-founder of Rx|X Consultants, an independent advisory group with over twenty years of 340B expertise in the 340B and healthcare industries. She can be reached at mwallack@rxxconsulting.com.

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