donnelly president pharmacy services ... - 340b...
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Statement of Conflicts of Interest Jim Donnelly has no actual or potential conflict of interest in relation to this presentation
Today’s AgendaBest Practices for 330 Grantee 340B Program Compliance
Know Your Program Policies and Procedures
Scope of Practice & Sliding Fee Discount Schedule Inventory Management Internal and Independent Audits
Findings/Resolutions
OPA Database Maintenance Preventing Diversion Preventing Duplicate Discounts Sliding Fee Program Contractual Arrangements
Learning Assessment Who is ultimately responsible for your 340B compliance?
A. Management Services ProviderB. Covered EntityC. Contracted PharmacyD. Manufacturers
Policies and Procedures Outline Your Program
Scope of Practice & Sliding Fee Discount Schedule Inventory Management Rules and Regulations
Understand Your Program Know your reports
Multiple Vendors
Verify/Audit Your Program Internal Audits Independent Audits Quality Improvement
Internal Audit Sample TemplateSite: *Entity Name*Contract Pharmacy: *Pharmacy Name*Sample Size: 30 ScriptsAuditors: ___________, _____________, _____________, _______________Period Covered: ____________ to ___________
Rx Number
Health Center Patient
Health Center
Prescriber
Encounter Documented
Medicaid/ MMCO/ ADAP/ FHP
Hard Copy/E‐Script
Reviewed (if applicable)
Yes No Yes No Yes No Yes No Yes No001 002 003 004 005
030
Common Audit Findings Ineligible Prescribers
“Moon‐Lighting” prescribers Filled date vs. written date
Ineligible Patients
Medicaid FFS processed inappropriately
Not Reporting Material Findings to the OPA
Internal Audit Findings/Resolutions
Quantify Issue(s) Clearly define the global impact of the actual findings on your
program
Complete Record Keeping for P&P Inclusion Internal Audit Finding & Resolution Documentation
Sample info Discovery Resolution Proactive Steps
Communicate to all applicable parties Compliance Officer/ Committee
Learning Assessment A prescriber is 340B eligible with a covered entity effective 6/1/2014 Which prescription is potentially eligible based on date written if the fill date is 7/15/2014?
Date Written:A. 5/1/14 B. 7/1/14C. 5/30/14
OPA Database Maintenance OPA database registration and recertification are requirements for participation in the 340B program
Register all contracted pharmacy arrangements under the covered entity’s parent OPA ID
Continually monitor and update the database and notify the OPA of all changes immediately Authorizing Official/Contact Person Medicaid Billing Information Child Site(s) and Contracted Pharmacy Arrangement(s)
Complete Annual Re‐certification
Preventing Diversion Understand the 340B Patient Definition
Solely Employed Prescribers Contracted Prescribers Per‐Diem Prescribers Referrals Drugs are within the scope of project for which 330 grant funding is provided
Patient Filter Tie prescriptions back to a medical encounter
Preventing Duplicate Discounts Medicaid Carve in: Covered Entities must have an agreement in
place with their state Medicaid agency in order to “carve‐in” Medicaid prescriptions for contract pharmacy arrangements. The agreement must be shared with the OPA
Medicaid Carve out: Covered Entities should work with their Management Services Provider to understand and ensure that Fee‐For‐Service Medicaid claims are kept out of the 340B process and Medicaid Managed Care claims are processed in accordance with State requirements if necessary.
Communicate with your state Medicaid Agency on a regular basis to ensure program integrity and compliance.
Sliding Fee Program Implement a discount program that works for patients and
pharmacies as seamlessly as possible across all pharmacy partnerships
The actual 340B price of a drug can be passed along to the patient if the locally prevailing charge for the drug is higher than the 340B drug cost 1 This discount does not need to be consistent with the rules outlined in
Sections VII.B and C of PIN 2014‐02
The Fee for Pharmacy Services must be discounted according to the rules outlined in Sections VII.B and C of PIN 2014‐021 At least 3 Discount Tiers
1.http://bphc.hrsa.gov/policiesregulations/policies/pin201402.html
Sliding Fee Discount Schedule
Verification of Patient
Eligibility
Confirmed <=200% FPG*
340B Cost + Dispensing Fee
SFDS** % Discount
>200% FPG Ineligible for SFDS
*Federal Poverty Guidelines : http://aspe.hhs.gov/poverty/14poverty.cfm **Sliding Fee Discount Schedule
Understand Your Contractual Arrangements
Review all contracts with Contracted Pharmacies for the following: General Business Rules Reporting Requirements and Expectations of the Pharmacy Inventory Monitoring/Understanding Dispensing Fees
Review all contracts with Management Services Providers for the following: Exclusivity Arrangements Term Length & Termination Fees Remediation/Slow Mover Processes & Timelines Fees associated with reversals or additional processing of claims
Summary Have Meaningful Policies & Procedures in Place
Conduct regular audits Self Report when Necessary
Keep OPA database current
Stay up to date on all Guidelines & Regulations Preventing Diversion and Duplicate Discounts
Know your Contractual Arrangements
Additional Questions?Jim Donnelly
Vice President of Pharmacy ServicesHudson Headwaters
9 Carey RoadQueensbury, NY 12804Phone: 518‐761‐[email protected]