Similar to the often used phrase “be sure this is included in your policy and procedures”, auditors get the same satisfaction by telling folks that “this needs to be included as part of your routine self-auditing”. It is easy to assume clean sites don’t need much attention in this area because of their very natureRead More
If you are in the 340B space, then it is likely you are well aware of the 340B contract pharmacy pricing battle occurring between 6 manufacturers and HHS. Let’s do a quick update of how we got here and the recent monumental shift from HHS that is giving covered entities much needed hope. It allRead More
Referral capture in the 340B world is not a new concept. What it requires is a Holmes and Watson investigative spirit, time, and most importantly…an eye focused to Compliance. In the 340B world, we live and die by the 340B patient definition. HRSA has given very specific guidelines that qualify a 340B prescription. First, theRead More
Many of you have been following and evaluating your options as multiple manufacturers have restricted contract pharmacy pricing for CEs. You probably also received our email communication in February describing a few exception opportunities that exist for AstraZeneca, Eli Lilly, Novo Nordisk, and Sanofi, if you do not have an inhouse pharmacy. If you didRead More
A topic we have covered in our client newsletter in the past, but is long overdue for a full discussion is 340B actual acquisition cost (AAC) requirements for fee-for-service (FFS) Medicaid billing in many states. In 340B audits we perform for clients, we review the AAC requirement and note if there is any risk. However,Read More
Historically, HRSA auditors have requested a list of eligible providers from covered entities during HRSA audits. Recently, however, HRSA auditors have been requesting that covered entities upload documents demonstrating that, for each audited utilization record, the prescriber was (at the time the medication was administered or prescription written) employed by, under contract with, or hadRead 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!