UPDATES ON 340B
2011
Brief Review of 340B
Initiated during Clinton administration
Who can participate? (FQHC, Family Planning, Ryan White, Black lung, Hemophilia, Urban Indian, TB, DSH, STD, Hawaiian health centers)
Newly Eligible—Critical Access Hospitals, Rural Referral
Centers, Sole Community Hospitals, Free Standing Cancer Hospitals, Children’s Hospitals
What does 340B Program provide?
How are prices derived?
What drugs are covered?
How does a CHC participate in
340B?
Register with Office of Pharmacy Affairs
Register with Prime Vendor
Why Participate in 340B Program?
Tremendous discounts on pharmaceuticals
Discounts on other items through Prime Vendor
Stretch dollars in order to serve vulnerable patients (low prices for uninsured)
340B Implementation Options
Can utilize in-house pharmacy
Can utilize Contract Pharmacy
Arrangement or Multiple Contract Pharmacies
Can obtain Alternative Method Demonstration Project approval
Office of Pharmacy Affairs (OPA)
Administers 340B Program
Serve as Federal resource for pharmacy practice
Develops innovative pharmacy service models
and supports technical assistance
Operating a 340B In-House
Pharmacy
Must have low inventory
Must have a sliding fee
Accept Medicaid, Medicare Part D, and various private insurance plans
Pfizer Share the Care
AZ and Me
Patient Assistance Programs
Optimizing 340B Purchasing
Strong P&T Committee
Formulary Management is imperative!
Inventory Control
Constantly check prices on 340B purchasing
Use wholesaler programs to always have access to lowest price
Use wholesaler to automatically update 340B quarterly prices
Utilize Prime Vendor program
Maximize use of extremely low prices ($0.01 items)
Prime Vendor Program
Saves money on major expensive items—oral
contraceptives, syringes, insulin, diabetic testing supplies, etc.
Negotiates sub-ceiling prices
Offers value added products and services Services offered at no cost to entity
Provides access to drug distribution solutions
Can save important dollars on printer cartridges, prescription bottles, flu vaccine, etc.
Prime Vendor has Advisory Committee for CHCs Pharmacy Flash Newsletter
Medicare Part D
Participate with Medicare Part D Plans!!
Establish your health center as “Medical
Home” for Medicare patients
Additional revenue
Pay Attention to Your Uninsured
Patients!
340B makes it possible to bring low cost medications to your patients.
Don’t send your uninsured patients to your
pharmacy with expensive prescriptions!
You have to pay attention to area $4.00 prescription prices!
Pharmacy—A Revenue Producer
CHCs should not use federal funds to subsidize patients above 200% of poverty level.
Should provide discounts based on income to those between 100% and 200% of poverty level.
Should provide “full discount” or “nominal price”
to those below 100% of poverty
Must charge adequate dispensing fees for
prescriptions (including Patient Assistance)
Third parties not entitled to 340B discount (except Medicaid)
Administration Must Understand
Pharmacy
Work closely with administration to
enhance their understanding of pharmacy costs and revenue potential
Administration must understand pharmacy recruiting and pharmacist salary levels.
Salaries have to be competitive! (Perks!)
Include pharmacists as part of management team.
Make a Contract Pharmacy Work!
Your Contract Pharmacy has to understand the 340B Program.
With the 340B Program, only the entity (CHC) can purchase the drugs. The drugs always belong to you!
Contract Pharmacy must understand that the only revenue that goes to the pharmacy should be the dispensing fee!
You want all third party prescriptions to create revenue for the CHC!
An outside contractor can be helpful with a Contract Pharmacy.
Don’t overlook formulary management and clinical pharmacy
services.
Pay attention to your uninsured patients.
You will need a competitive low-prices prescription plan ($4.00)
Your Contract Pharmacy arrangement should produce revenue for the CHC.
Patient Safety and Clinical
Pharmacy Services Collaborative
HRSA initiative to improve patient safety issues and initiate greater level of clinical pharmacy services in the safety net
environment
Opportunity to join now for a new collaborative.
Great opportunity to change pharmacy practice in CHCs and to greatly enhance patient safety
Future of 340B
Every agency wants it!
Every state wants greater access to 340B prices for state Medicaid programs, prisons, etc.
Pharmaceutical industry does not want expansion! Possible deeper discounts?
NACHC wants to assist more health centers in understanding 340B and how to utilize the program!
Changes for PSSC
Still has Call-Center Support
Offers Technical Support
Policy interpretation
Networking opportunities
340B Peer to Peer Program
2011 Leading Practice Sites
Carolinas Medical Center
Children’s Health Center of Atlanta Community Care/Central Health
Harris County Hospital District
Health Partners of Western Ohio
Holyoke Health Center, Inc.
New Hanover Regional Medical Center
Park Ridge Health
Piedmont Health Services, Inc.
Shands Jacksonville
NCCHCA Pharmacy Directors
Group
We have a small group of Pharmacy Directors that meet quarterly.
Need more Pharmacists to join—even by
telephone if possible.
Want to create a viable organization that can assist all CHCs in N.C. with pharmacy services.
Contacts:
HRSA Office of Pharmacy Affairs
www.hrsa.gov/opa
Pharmacy Services Support Center
1-800-628-6297 pssc.aphanet.org
Prime Vendor Program 1-888-340-2787
Presenter: Carl D. Taylor, Pharmacist
Director of Pharmacy Services, Piedmont Health Services, Inc. Chapel Hill, N.C.
Consultant, HRSA Pharmacy Services Support Center
Clinical Assistant Professor, UNC School of Pharmacy
Tel. 919-537-7493