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The PHS 340B Drug Pricing Program

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340B DRUG

PRICING PROGRAM:

Improving access to affordable

medications.

Harry P. Hagel, RPh, MS

Senior Director

HRSA Pharmacy Services Support Center American Pharmacists Association

August 16, 2006

The PHS 340B Drug

Pricing Program

ƒ

Established in 1992

ƒ

Provides discounts on outpatient drugs

to covered entities

ƒ

Manufacturers that participate in

Medicaid must also sign an agreement

to participate in 340B Drug Pricing

Program

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Why 340B?

ƒ

Reduce prescription drug expenditures

by safety net providers in order to:

ƒ Expand health services access to:

ƒ Low-income individuals/families

ƒ Vulnerable populations

ƒ Reduce taxpayer burden

Estimated Prices For Selected

Public Purchasers, as Percent AWP

Stephen Schondelmeyer, PRIME Institute, University of Minnesota (2001)

100.0% 80.0% 67.9% 60.5% 51.7% 49.0% 47.9% 34.6% 0% 20% 40% 60% 80% 100% AWP AMP Medicaid (Min.) Medicaid Net FSS 340B FCP VA Contract

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340B Covered-Entities

ƒ Consolidated Health Centers – (FQHC’s and Look-alikes) ƒ Disproportionate Share Hospitals

ƒ STD and TB Clinics

ƒ Title X Family Planning Clinics

ƒ AIDS clinics and drug purchasing programs ƒ Urban Indian clinics/638 tribal centers ƒ Migrant health centers

ƒ Health centers for public housing ƒ Black lung clinics

ƒ Hemophilia treatment centers ƒ Native Hawaiian health centers ƒ 340s school-based programs

340B Basics: Requirements

and Prohibitions

ƒ

Definition of a patient

ƒ Established relationship with covered-entity

ƒ Care from employed or contracted provider

ƒ Services provided consistent with funding

ƒ

Resale or transfer

ƒ

Audits and record keeping

ƒ

Group purchasing discounts

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State Optimization of 340B:

Reasons to Consider

ƒ

Increased prescription drug utilization

ƒ

Increased numbers of uninsured and

underinsured

ƒ

Skyrocketing health care costs

ƒ

Dual eligible transition to Medicare

ƒ

Growth in 340B program utilization,

value and support

State Optimization of 340B:

Financial Savings

ƒ

Heinz Foundation Report (Rhode

Island)

ƒ Comprehensive statewide evaluation

ƒ Pre-rebate Medicaid to 340B comparison

ƒ Savings vary by program

ƒ Implementation and on-going administration costs

ƒ Net savings estimated at $2M first year

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State Optimization of 340B:

Financial Savings

ƒ

Wellpartner

tm

Analysis – California

Medicaid

ƒ Managed Medicaid plan

ƒ Post-rebate to 340B comparison

ƒ Adjusted dispensing fee

ƒ 12.2% savings below net Medicaid price

www.nlarx.org/policy/pdfs/Oregon340BPricing_ analysis.pdf

State Optimization of 340B

Legislative Strategies

ƒ Evaluation and Study

ƒ Health Center Expansion

ƒ General Funding

ƒ Provider Contracting

ƒ Formulary Coordination

ƒ Modified Reimbursements

ƒ Mandated 340B/Prime Vendor Participation www.ncsl.org/programs/health/drug340b.htm

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State Optimization of 340B:

Challenges to Address

ƒ

Underutilization by covered-entities

ƒ

Procurement policy restrictions

ƒ

Need for program adherence

ƒ

Provider relationships/collaboration

ƒ

Funding

ƒ

Evaluation methods

ƒ

On-going administration

State Optimization of 340B:

Key Implementation Steps:

Step 1 – Evaluate opportunity and potential impact from both a financial and system service delivery perspective.

Step 2 – Identify and resolve regulatory barriers to implementation.

Step 3 – Implement measures to facilitate program participation and utilization of 340B resources.

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State Optimization of 340B:

Resources

ƒ

OPA Federal Team

ƒ

Pharmacy Services

Support Center

(PSSC)

ƒ

Prime Vendor

Program (PVP)

340B Program PSSC PVP OPA

Office of Pharmacy Affairs

Mission, Functions and Funding

Federal Register 9/21/2004

ƒ Promote access to (Comprehensive Pharmacy Services) clinically and cost effective pharmacy services through:

ƒ Maximizing the value of participation in 340B

ƒ Developing innovative pharmacy services

ƒ Being a Federal resource for pharmacy practice

ƒ $2.97 Million Line Item in FY2007

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Annual Growth of Section 340B

Covered Entity Sites by Agency

0 1,000 2,000 3,000 4,000 5,000 6,000 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 (Projected) 2008 (Projected)

Year (as of July 1)

N u m b er o f c o ve re d en ti ti es

CMS/ HRSA DSH CDC (STD/TB) IHS (638 & Urban) OS Family Planning HRSA Grantees and FQHC-LA

PVP Mission/Goals

ƒ

Improve access to affordable

medications for covered entities

and their patients

ƒ

Primary goals:

ƒLower supply costs

ƒEfficient drug distribution solutions

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Benefits of Single Prime

Vendor

ƒ

Aggregation and leveraging of $4 billion

in outpatient/340B purchases

ƒ

Covered-entities benefit from volume

and therapy specific market share.

ƒ

Cost-effective sub-ceiling contracting.

ƒ

Centralized experience and resources

ƒ

Improved program integrity.

340B Prime Vendor Program Participants

by Effective Date (cumulative, as of 08/07/06)

31 268 430 668 913 1293 1600 1961 2067 2384 2673 2818 0 500 1000 1500 2000 2500 3000 N o . of P a rt ic ip a n ts 2004 Jan 2004 Apr 2004 Jul 2004 Oct 2005 Jan 2005 Apr 2005 July 2005 Oct 2006 Jan 2006 Apr 2006 Jul 2006 Aug Calendar Quarter

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PVP Participants by Entity Type

(as of 08/07/06 – 2818 participants) Other, 11 Tuberculosis , 159 Sexually Transmitted Disease Treatment, 232 Community Health Center, 880 Disproportionate Share Hospitals, 917 Title X Family Planning, 537 HIV Programs, 81

Pharmacy Services Support

Center

ƒ Established through a contract between APhA and HRSA, signed September 27, 2002.

ƒ Enhances Office of Pharmacy Affairs (OPA) resources to optimize the value of the 340B program in order to provide affordable, comprehensive pharmacy services that

improve medication use and advance patient care and patient access to affordable drugs.

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Clinically and Cost-Effective

Pharmacy Services

OPERATIONS ACCESS QUALITY OUTCOMES

Clinically and Cost Effective Pharmacy

Services

ƒ Drug formulary management

ƒ Patient-specific counseling, education and monitoring

ƒ Medication education for providers

ƒ Health promotion seminars

ƒ Collaborative disease management

ƒ Provide immunizations

ƒ Undertake drug utilization review

Maximizing

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Pharmacy Services Support

Center

ƒ Information management

ƒ Organizing pharmacy expertise and resources

ƒ Responding to 340B inquiries

ƒ Providing technical assistance

ƒ Policy analysis

ƒ Monitoring pertinent policy developments

ƒ Communication and education on policy issues

and Medicare

ƒ Networking

ƒ Communication and education

ƒ Project development

CONTACT INFORMATION

Office of Pharmacy Affairs

Phone: 301-594-4353 or 1-800-628-6297

Email: [email protected]/opa

Web: www.hrsa.gov/opa

HRSA Pharmacy Services Support Center

Phone: 1-800-628-6297

Email: [email protected]

Web: http://pssc.aphanet.org

Prime Vendor Program

References

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