It’s registration time again. That’s right. All aboard the 340B train. All those that qualified in October are now eligible and those that missed the deadline in October have until the 15th of January to register. Let me tell you, the word is out. October 2014’s registration had 4,158 CE’s and CP’s that registered. Well, it is a great program. And there are some great benefits for the covered entities as well as the contracted pharmacies, as long as you follow the guidelines, the rules set in place and you watch your back. Between the HRSA regulations, the wholesalers, the manufacturers and the software vendors, it’s a tricky cup of tea out there.
So, for those of you that have decided to join in on the fun, a few words of advice….
Pick a 340B software vendor that is right for you and verify that they are providing you the best service and most compliant product possible. Make sure that they have implemented your hospitals and contract pharmacies correctly. Check your settings and make sure your scripts and your hospital charges/associated NDC’s are being tested accurately. Check to see that your catalogs are being updated on a regular basis so that you are receiving the correct pricing offered by your wholesaler.
Have an audit plan ready and document EVERYTHING. There are so many things that can easily get by you and when that audit notice appears, you don’t want to wonder where everything is or why everything is the way it is. Your policies and procedures are the most crucial part of your program. Put them into place and train your staff on them, keeping them updated regularly. Have an outside auditor come in and check out your program. Having another perspective and another set of eyes to look things over is always helpful, not to mention, expected by HRSA as a best practice.
Make certain you are doing everything you can to stay in compliance with HRSA. If you are carve-out, contact your state Medicaid agency regularly to make sure you have an updated listing of all the Medicaid plans (and their corresponding BIN-PCN-GROUP numbers) that are receiving rebates from the state.
For those out there wanting contract pharmacies, before you enter into any agreement make sure that the dispensing fee and the model that you agree upon is beneficial to BOTH you and the contract pharmacy. It won’t do either of you any good to enter into something that causes cash flow problems and ends up with both parties unhappy and cancelling the contract. Also keep in mind that as business changes around the contract pharmacy, the arrangement may need to be re-evaluated to see if the relationship is still profitable. This might be something you want to do on an annual or semi-annual basis.
The latest commotion coming down from the hill in regards to the 340B program seems to be around its intent. There are a lot of people looking at what is being done with the money generated from participation in this program. So it might be a good idea, if you don’t have it documented already, to start thinking about how you are putting those dollars back into the hospital or back into the community through prevention programs or service projects that assist some of the more vulnerable or lower income patients in your area. You need to be able to show how the 340B program is directly contributing to your hospital and community. That being said, good luck and welcome to 340B!