Also, I recently had the pleasure of meeting Amanda in New Orleans at the annual NCPA convention. She is a wonderful person and Pharmapreneur seeking to help community pharmacy navigate the somewhat murky depths of the 340B programs.
Here is our interview:
What is the 340B program and how does it affect community pharmacies?
The 340B Drug Discount Program was established in 1992 by Congress as part of the Veterans Health Care Act. It requires manufacturers to provide discounts on outpatient drugs purchased by qualifying health systems known as “covered entities” serving vulnerable patient populations. The savings realized allow the healthcare facilities to reach more eligible patients and provide more comprehensive services and improve access to medication.
Community pharmacies stand to benefit greatly from the 340B program.
They can partner with covered entities, or CEs, to act as their agent with 340B eligible patients. Pharmacies negotiate a fee for each eligible claim. These claims, on average, have higher margins than non 340B claims. Revenue received by third party and copayments is passed to the CE minus the negotiated fee. In return the CE purchases the item dispensed at the 340B price and replenishes the pharmacy’s inventory.
What made you interested in helping pharmacies with 340B?
340B programs have great potential to benefit community pharmacy but it’s not a slam dunk. I’ve worked on the administrative side as a 340B Administrator, and I’ve managed several 340B contract pharmacies. I have witnessed programs benefiting pharmacies tremendously and others that were detrimental.
The world of 340B pharmacy is a complex one, requiring that 340B programs be structured correctly and monitored closely. The benefits for both the covered entity and contract pharmacy are great, but so are the risks. Someone who understands 340B best practices must vigilantly monitor the program.
How does your company work with those pharmacies?
We at Secure 340B see ourselves in an advisory role; a resource for information, education, tools, data analytics and most importantly support for our independent pharmacists. We want our pharmacists to understand the program and be certain it is positively impacting their business.
Secure340B is evidence based.
Plain and simple, it’s data that drives our recommendations. This commitment to evidence means that we can accurately demonstrate how a program is performing and then offer solid recommendations for improvement. We also complete retrospective review to identify claims impacted by DIR fees or inventory owed to the pharmacy.
Why is transparency important in the program?
Most pharmacy owners can’t say exactly how the 340B program is impacting them financially. There are so many unknowns in pharmacy in general with reimbursement, drug pricing, and DIR fees that it becomes essential to keep this portion absolutely transparent. At Secure340B our goal is for both the pharmacy and the CE to understand the data and be absolutely clear.
How can pharmacies implement and monitor a sustainable 340B program?
It may be a well-worn phrase but it still bears repeating: When it comes to understanding and managing a successful 340B program, knowledge is power. Here’s a checklist to help sharpen your thinking.
- Determine if the dispensing fee is appropriate. There is not a ‘one fee fits all’ solution. The dispensing fee should be based on the program type, all claims or profit only, and mix of claims qualifying. On average, the dispensing fee should be more than the pharmacy would have realized without 340B including rebates.
- Identify claims with DIR fees adjusted after payment has been made to the covered entity and reconcile. If not, the pharmacy is making payment back to the PBM on revenue already passed to the covered entity.
- Track un-replenished inventory. 340B administrators have true-up processes but often inventory remains due for partial packages not matching an exact claim.
- Monitor inventory levels to ensure inventory isn’t increasing more than needed. Send back 340B inventory received in excess on the pharmacy’s retail account.
- Know what inventory is being shipped on the 340B account and cut the retail order to prevent inventory swell.
- Review terms of agreement. Payment from pharmacy to covered entity should not be expected until after a reasonable time to obtain reimbursement from third party.
As a pharmacist-entrepreneur (In our Community we identify ourselves as “pharmapreneurs”), what has drawn you to build a business of your own?
I love independent pharmacy and thrive on using the knowledge I have learned to help them continue to succeed and make a difference in our communities.
I want to thank Amanda for shedding some light on 340B for us!
This new blog series will focus on tools that help community pharmacy implement and integrate enhanced patient services.
The new series is called the Community Pharmacy Toolkit…
Some of these tools focus on streamlining workflow, integrating new services, improving interoperability, making for easier documentation or even just some services that I think are really cool.
If you’d like to stay up to date and be notified of each new article in this series, join the Pharmapreneur Community Newsletter.