When you think of compliance pitfalls in the 340B Program, contract pharmacy immediately comes to mind. Contract pharmacy is one of the highest compliance risk areas of the 340B program; however, the reward of better serving our vulnerable and underserved patients to many is well worth the risk. Contract pharmacies have allowed covered entities toRead More
Carve-In Medicaid Entities: At a minimum, list the NPI of the entity for each registered site on the HRSA database and subsequently the Medicaid exclusion file (MEF). Covered entities (CEs) with multiple child sites will need to confirm the NPI number used for billing at each site as it might be different than the parentRead More
Well, big news out yesterday. As of 1/30/2017, the 340B Omnibus Guidance is officially withdrawn. Where does that leave us? Well, that brings be to my second topic, the 340B Winter Coalition Conference. I am in my seat on our airplane to San Francisco. I am excited for this conference, as the legislative sessions willRead More
For those who have had an audit from Turnkey, you already know how important it is to have a strategy in place for every drug in every location that ensures 340B compliance. At the very least, this should include ensuring that patient-specific and drug-specific auditable records are maintained and available, that 340B drugs are onlyRead More
When your split billing company suggests it is Ok to include Managed Care Medicaid claims for contract pharmacy, please consider the following: Allowing managed (MCO) Medicaid 340B accumulations, for contract pharmacy, is not worth the risk because at the end of the day it would likely be the covered entity that would have to workRead More
Covered entities are often faced with trying to decide whether or not a particular product is a 340B drug for which PHS/340B pricing benefits and regulations apply. Sometimes this can be confusing and tedious. 340B Drug Pricing Program under section 340B of the Public Health Services Act (PHS) only applies to covered outpatient drugs (CODs),Read More
The Turnkey team of Rich and Rich clearly have extensive hospital experience with 340B and were able to quickly understand our operational issues and provide clear recommendations. When our team had questions months later they promptly responded to each request with thoughtful and specific advice.
We have contracted Turnkey Rx Solutions for almost a year now. We're very impressed with the work they have been able to provide us. They understand the high standards that our health system has and have been the efficient delivering. I highly recommend working with them.
Turnkey Solutions was well prepared for our mock audit and knew just what questions to ask and where to look for improvement opportunities. They easily found the needles in the haystack and took the time to understand our practice to make the best suggestions for improvement. ... It was a delight to work with them and I will contract with them again in the future.
We have been extremely satisfied with the assistance Turnkey Pharmacy Solutions has provided to us as our 340B program has expanded. We have worked with Rich and Rob and find them to be extremely knowledgeable, thorough, and personable. Their mission was to identify and minimize any potential risk areas within our 340B program. As a result, we feel very confident in our processes.
TurnKey is very knowledgeable of the 340B Program. They identified potential risk areas for our organization and provided us with the necessary corrective action. Thanks to TurnKey, we identified and addressed those risk areas and are now better prepared for a HRSA Audit.
The information and resources that were provided through the audit process with Turnkey have been invaluable. We will definitely continue to work with them in the future to ensure our program compliance.
Together, we can get your 340B Program HRSA compliant!