340B Updates- Happy Thanksgiving!

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340B Updates- Happy Thanksgiving!

We often have our name mistaken for Turkey (instead of Turnkey), and during this time of the year, we totally embrace it! Happy Thanksgiving!!!

-The Turnkey Pharmacy Solutions Team

Well, it has been awhile since you have heard from me. Some nice posts by Jen Cook and Jennifer Hagen since my last one. Speaking of which, Turnkey is super excited to have Jennifer Hagen on the Turnkey team. She became full-time with us in October. She just stepped down from her post as the ambulatory service pharmacy director for a large DSH hospital. She has experience as a 340B faculty member and with peer-to-peer. I must admit, she is starting to make me look bad!

OK, some updates for you:

HRSA 340B Audits – We have word of the first Bizzell/APhA audits occurring the first week of January! If you didn’t hear, HRSA is outsourcing the onsite audit portion, and the Bizzell Group has the contract. They are working with APhA to resource the staff for the audit. We were not sure how long it would take to operationalize this process, and yikes, that was fast. I am very interested in seeing how the auditing process goes with pharmacy trained personnel. As a shameless plug, all the more reason to have your 340B independent audit be led by a 340B trained pharmacist, which of course is exactly what you get with a Turnkey audit.

We saw the data request, and it appears similar to the previous data requests, so not too much change there (just in case someone from HRSA or APhA reads this, I still think you should separate the administered drug data and the retail script data requests, as the data elements are different and it is confusing to pull these data sets as currently requested. Of course, this is just free advice, and may not be worth much more than that).

340B Omnibus Guidance – Just saw some information from Essential Hospitals. I have heard rumors, but here is what they said:

“Knowledgeable government sources have told the association that the Obama administration, as of now, will not move forward with final 340B “mega-guidance” before its term ends on Inauguration Day, Jan. 20.”

I am not sure if this is a bummer or not (or if is 100% accurate). I still think of the final 340B Omnibus Guidance as a band aid that needs to be ripped off. So, that means we are keeping the band aid on and delaying the inevitable.

Winter 340B Coalition Conference and Turnkey: Turnkey will have a booth at the 340B conference in February 2017 in San Francisco and we very much look forward to meeting as many of you as possible. If you happen to read this article and are attending, find us at our booth and we will have a special gift for you.

It has been a crazy year, we have conducted over 100 independent 340B audits, been on site for numerous HRSA audits, and have doubled the size of our team. I am sure 2017 will be even more fun and we look forward to sharing it with you!


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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