340B providers are facing an unprecedented number of challenges. 340B program managers are forced to react to these changes every day. Having access to clear and understandable data and developing strong relationships with partners in the 340B supply chain are critical to running an effective program. 340B leaders should consider the individual pieces of each 340B program, what relationships exist for each piece and why it is important to get what is needed from these partners to run the program optimally and effectively.
Evaluating Your Partners
340B program managers should look at the partners with whom they routinely work to make their program function. First and foremost, it is important to know which locations within the covered entity is eligible. Eligible locations, providers and patients lay the foundation for the 340B program and assist in determining with which partners to work. Contract pharmacy relationships, drug access, and patient plan utilization are a few key elements to consider in driving an optimal and compliant program.
Pharmaceutical Manufacturer And Wholesaler Relationships
An active area of concern and change right now is the relationship between 340B covered entities and pharmaceutical manufacturers and wholesalers. These relationships can directly influence the success of a 340B program. Actively engaging with the wholesaler will help impact the program in many ways. Program managers will have a platform to understand if their facility or facilities are receiving 340B pricing for all active drugs. Reviewing the list of 340B drugs they have access to will help ensure program managers are aware and actively capturing all eligible claims. It is difficult to capture a claim for any national drug code (NDC) dispensed if the 340B pricing is not listed within a program’s file.
Determine if an additional wholesaler setup is needed. An additional wholesaler may help gain access to all eligible drugs being prescribed within the facility. For example, if a particular limited distribution drug (LDD) is only available with one wholesaler with whom an active account does not exist, the 340B program manager will need to secure an additional relationship and account set up with them to gain access to that specific drug.
Additionally, it is important for program managers to know their account setups and how each is being used. They should make sure to have clear line of sight into their 340B, group purchasing organization (GPO) and wholesale acquisition cost (WAC) accounts. It is also important to document when it is appropriate to use the respective accounts. For 340B accounts, program managers should confirm they have access to see when 340B orders are placed and which prescriptions are driving the respective orders.
Having strong partnerships with wholesalers will allow each program manager to make more informed decisions, especially when it comes to current industry items like pricing restrictions, data uploads or single contract pharmacy utilization.
Selecting The Right Contract Pharmacy Partner
Choosing the right contract pharmacy arrangements can be daunting, overwhelming and a lot of work. Looking at the patient base and drug utilization can help narrow the choice.
Determine which pharmacies current patients use. Depending on the patients served, drug access may also play into the contract pharmacy arrangement. Evaluate the pharmacies in the current network setup. Make sure the drugs being prescribed are available at the contract pharmacies within the network. If specialty patients are being serviced, make sure the contract pharmacies in the network have access to the disease-state-specific medications. LDD availability can influence where patients receive their medications.
With complex disease states and medications, program managers should ask the question: Do the contract pharmacies provide the clinical needs of the patients? Depending on the condition of each patient, he or she may need additional clinical care from the pharmacy. For example, patients may need to learn how to use an injectable medication or need resources for medication management.
Maintaining a relationship with contract pharmacies can assist in visibility into referral tracking and medication adherence management. Work with the contract pharmacies and vendors to determine what reporting or data is available. At the end of the day, the goal of the program is to stretch scarce resources and expand access to better serve the patient and the community.
Patient Payer Utilization
Just like pharmacy usage, patient payer utilization may vary widely. No matter the payer, it is the responsibility of the covered entity to prevent duplicate discounts. Having insight into which claims are being captured will help determine if duplicate discounts are being prevented. If a pharmacy benefit manager (PBM) change occurs, program managers should investigate how it will impact the 340B program in place for the covered entity. Decide if the program will carve in or out the 340B program for Medicaid Fee for Service patients. Upon that decision, detail how the carve in or out should occur. Document all findings, keep records and be able to address how the program is functioning.
Reflecting On Your Own Program
Take a minute and reflect on the 340B program in the specific covered entity as it stands today. Are all tools and resources needed to run the program available? What current controls are in place? Which locations are eligible to participate in the 340B program? Are there claims capturing for each of those eligible areas? Are claims being inspected and verified that they meet program-specific criteria? Have the drug needs and plan access of the patients been reviewed?
After thinking through all these pieces, make sure it is documented in your 340B policy and procedures. Review policies and procedures as often as needed, updating when changes occur. By doing so, program due diligence is maintained to demonstrate a compliant program.
With any of the relationships, make sure to choose partners who will help the 340B program succeed. Don’t be afraid to ask questions. Choose partners who will enhance the ability to see the program holistically, expand the program’s reach and allow the covered entity to maximize the opportunity to help patients.
ShaiAnn Howard is Director, Health Systems Solutions & Decision Science for AllianceRx Walgreens Pharmacy. She can be reached at firstname.lastname@example.org.