340B/HRSA EMERGENCY ENROLLMENT

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340B/HRSA EMERGENCY ENROLLMENT

Some call it Novel Coronavirus SARS-CoV-2.  Others call it Corona Virus disease of 2019. Many like to say Covid-19 or just plain Corona. Anyway you say it, it brings up many emotions for nearly every American. Everyone in our society has been impacted in some way. The virus has thrown the Healthcare industry into near chaos since the virus reached our shores earlier this year.  

To the shock and dismay of many, the AHA is estimating that American hospitals alone are losing $50 Billion a month.  Yep, that is billion…with a capital B.  The impact is being felt especially hard by our Safety Hospitals, who already run on razor thin margins.

Since we do not have a genie in a bottle (or a vaccine), what can our 340B community do to help our facilities?  HRSA is now allowing several options and opportunities  to provide help to our Safety Net Providers. 

  1. Entity/Child Site Registration: They are allowing immediate enrollment into the 340B program.  Several of our clients have taken advantage of this, and can make a huge impact to the entity, especially in the short term.  What does an entity have to do?   
    • Reach out to Apexus (apexusanswers@340Bpvp.com) to answer a few simple questions regarding the reason for the off-cycle registration, and the impact Covid-19 is having on the entity.  The questions and the reason for the off-cycle enrollment must be related to the hardships incurred from Covid-19.  
    • Explain the urgency of the request for the enrollment.  Confirm the clinic/location is under the reimbursable section of the latest filed Medicare Cost Report.
    • All other enrollment requirements are still required ( i.e., DSH%, and GPO prohibition, if applicable etc.).
  2. Contract Pharmacy Registration:  HRSA is also allowing off-cycle contract pharmacy enrollment.
    • Similar process, reach out to Apexus (apexusanswers@340Bpvp.com) to answer a few simple questions.

HRSA has been supportive of allowing entities to shift, expand, and reorganize departments and locations in order to accommodate the influx of Covid-19 patients.  For example, some entities are creating new clinics just for Covid patients.  Several have separated their Emergency departments into two,  one for Covid patients and one for non-Covid patients.  

As usual, it is critical that these changes/moves/updates are documented in your policies (did you receive a copy of Turnkey’s Emergency Policy last month?  If not, reach out)!  Also, auditable records demonstrating 3430B compliance for each patient must be kept.  

Over the last two months, we have had several entities reach out to see if and how Telemedicine encounters could be counted as qualified 340B encounters.  The short answer is yes, but again, it   must be in your policies, and auditable records must be maintained.  Also, see Rich Buchers’ Blog from last month!  As he says, “it reads like a John Grisham novel”.

These are unprecedented times for our 340B hospitals, clinics and safety net providers.  From the Turnkey and Elevate340B team, a big THANK YOU to all of the front line Healthcare workers.  


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