340B Coalition Day 1 of 3 & Update

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340B Coalition Day 1 of 3 & Update

Pre-Conference Work Shop

340B Conference in DCQuick Update on Turnkey Pharmacy Solutions: Wow, I cannot believe it is conference time already. We intended to get a few more blog articles out before now, but work got in the way (I hate it when that happens). This is a good thing, since it means we are onsite with covered entities and gaining more and more experience to share (as long as we get to the sharing part). We have been onsite for 5 HRSA audits in the last few months as well as many 340B independent audits. We actually have plans to share what we are seeing, both best practice and compliance concerns. We are going to share this in the next few months, and are deciding the best way to do this (maybe a free Webinar). With Rich Bucher being full-time and adding Roxanne Nevarez to our auditing team full-time, we are at a good place for supporting more clients and are now at this conference with a booth (and hopefully I do not have another 8-week stretch of travel, which I must thank my wife for putting up with me for that period of time).

Before I get into some highlights, I must send some love to 340B Health (a.k.a., SNHPA – still getting used to the name change). They put a lot of time and effort into making this conference both educational and a great venue to attend. My highlights below are simply that, some keys I pulled out to share. There is so much more content and tracks for education, I am covering a small fraction of the content in our blog. I know travel budgets are tough, but strongly recommend you attend one or both of the 340B Coalition meetings in the future (plus we hand out really awesome Utah mint truffle chocolates at our booth).

Pre-Conference – Implementing Effective Compliance Plans:

Started with Kevin Jones (he and I were both pharmacy directors of 340B hospitals at the same time at Intermountain Healthcare). Kevin shared what he does from his new role as the 340B Program Director. They have a robust compliance plan, and here is the biggest key I took away: Education is key and they do a quarterly education (off-site location and runs about 6 hours) training. We started this when I was still there, and it provides education on key updates and for new staff supporting the program to learn quickly what they need to know. Great idea!

Next was Shaun Phillips from Bronson Battle Creek Hospital. Love this guy, he was awesome. Shared details about their program and what they do for compliance. Shaun highlighted the need to have a dedicated 340B Analyst to support their program. He also noted the difficulty in finding the right person: Pharmacists are expensive, wanted some pharmacy knowledge, accounting background, and some general idea about 340B at minimum. They finally found the right person and as luck would have it, received their HRSA audit letter. That is baptism by fire! Shaun is right though, you need a dedicated resource for most medium to large covered entity sites (partial resource if you are smaller).

Last was Cynthia Williams from Riverside Health System. She hit on another key topic that is related to split-billing software maintenance. This is a key for us as well. If you are new to the program, do not underestimate the time and resource it will take to maintain a split billing software system. Cynthia also added a 340B Analyst, and stated “this should be a no brainer.” However, when your system is doing a RIF (reduction in force) it is still a tough ask! Cynthia educated CFO and COO on program complexity, growth, and financial impact. She used resources with 340B Health and Apexus as well. They ultimately hired a pharmacy technician buyer with significant 340B experience. Nice work Cynthia!

All three speakers mentioned having a 340B Oversight committee – we feel this is a Best Practice for all covered entity organizations. This committee should have C-Suite leadership and pharmacy, finance, and IT support as well. Also good to add compliance and legal when needed. We recommend meeting quarterly.

Okay, that was the pre-conference workshop for us. More to come on when we officially start the conference this afternoon. Aloha, -Rob

About Author

Rob Nahoopii, PharmD, MS, 340B ACE

Experience as a Director of Pharmacy for a 400 bed DSH hospital (also served as a regional director of pharmacy). Rob has presented at many 340B University sessions and on the topic of 340B at numerous other conferences around the country. He has provided many external 340B audits for various covered entity types, and onsite support for multiple 340B HRSA audits. Rob is part of our 340B independent auditing team and also supports our maintenance clients and 340B implementation. His perspective is from front line pharmacy leadership and program compliance.

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