HRSA Audit Highlights

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HRSA Audit Highlights

We have been busy supporting our wonderful clients on HRSA 340B audits almost constantly throughout the year, but in the recent months we have seen some changes. Here is a quick update on things we have seen that may catch you off guard if you’re not prepared.

First, whether you are carve-in or carve-out, you will very likely be asked to provide UB04/HCFA 1500 billing claim forms for all 28-33 sampled claims. Additionally, you will be asked to provide UB04 claim forms for all out-of-state Medicaid plans you have billed and to do this, the auditor will go outside of the audit period, as far back as necessary to complete the request.

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The Medicaid Challenge

It was great to see everyone at the 340B Coalition in San Diego last month. Thank you to everyone that stopped by Turnkey’s booth to say hello. We hope you had the chance to find out more about Turnkey’s affiliates, cutting-edge central supply chain service, Trulla, and the newly updated optimization service, Elevate.

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Transparency for Everyone

In 2018, meaningful conversations around 340B have included transparency. Many covered entities, large and small, have embraced the notion of transparency in their 340B program. In order to protect the 340B program, CEs have put pen to paper and began telling their stores of how 340B savings are being utilized. I think we can agree, we have all been waiting for manufacturer to follow suit.

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New 340B Stewardship Principles

This summer’s Congressional 340B hearings drew attention to the need for covered entities to be able to speak to the use of their 340B savings in alignment with program intent. While the documentation and demonstrated use of savings is currently not required by statue for hospitals, many of the grantee covered entity types are already required to demonstrate that all resources generated through the 340B program are used to expand and support services within the scope of their grant. Many covered entities, including hospitals have developed “Use of Savings” documents highlighting the valuable services and programs supported by 340B savings and have shared them with their communities and congressional delegations. The sharing of the importance of the 340B program has gone a long way to build program support.

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American Patients First

A Review of: American Patients First: The Trump Administration Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs – May 2018

Is the Trump Administration Blueprint to lower drug costs really about reducing drug prices or reducing drug spending?  According to President Trump, “Prices will come down.” Alex Azar further explains,

“When it comes to the cost of prescription drugs, our healthcare system faces four major challenges:  high list prices for drugs; seniors and government programs overpaying for drugs due to lack of the latest negotiation tools; high and rising out-of- pocket costs for consumers; and foreign governments free-riding off of American investment in innovation.”

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If you do not take the time to tell your story, someone else will!

It was impossible to walk away from this summer’s coalition meeting and not feel compelled to tell your own 340B story. If you read our newsletters, we have not stopped blogging about this!  As you made your way through the many informative sessions at the 340B coalition, you heard the many stories of the positive and often lifesaving impact that 340B has on vulnerable patients. Unfortunately, these stories were told primarily within the confines of the Omni Hotel. After hearing from Sectary Azar, it was even more evident that not enough stories of the good work being done via the 340B program are not reaching the members of our administration.

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Matsui Introduces Legislation in Support of 340B Program

If you are reading this blog, you are probably a big fan of the 340B program, and can witness day after day the benefit it brings to your covered entity and your patients. As we travel the country, our team sees the enormous benefit it brings every day.  If you are like me, you often lie in bed at night and wonder, “what can I do to support the 340B program?”  Here is your chance!

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Your 340B Universe Narrative

When HRSA sends a data request to a covered entity (CE) being audited, the request includes a description of the CE’s 340B universe that includes a narrative, by which the data was gathered, and any limitations or exclusions. Based on our experience supporting HRSA audits, auditors often rely on this narrative to some extent when planning and conducting their onsite audit. Therefore, creating a 340B universe narrative provides you with an excellent opportunity to help facilitate and guide these and other external and internal audits in a manner that promotes efficiency and appropriate focus. Perhaps more importantly, however, creating a narrative is a critical step that you can take to help ensure that you have sufficient oversight of your program. Managing your program should start with being able to accurately describe it in sufficient detail. If you do not understand your program and cannot accurately describe it, you cannot effectively manage it. Drafting a 340B universe narrative forces you to describe your program, and it can be a catalyst for addressing and clarifying confusing or unfamiliar locations and practices, engaging key stakeholders, and developing comprehensive and more detailed documentation.

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A Nerd and Her Calculator

Well it’s my turn to write the blarticle again. I know, I hear your disappointment. I just am not a writer. And I always focus on the politics, nothing personal like the amazing Jen Cook. So it should come as no surprise that again, this blarticle will be political. I wanted to write about the White House Correspondents Dinner but that has little to do with 340B. All I will say is, who caught it? What are your thoughts? Email me! Or text me (‘cause I’m a millennial and any truly verbal way of communication is too aggressive (801-830-5206)).

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The Face of 340B

Life-changing experiences can manifest in many forms.  For me, it was a crooked smile.

A heart in your throat, can’t breathe, “Please, no”, crooked smile of my sweetheart having a stroke at 38.  Four days in the ICU with no answers and a CT scan documenting damage in his brain the size of a peach pit.  Two MRIs, CT scan, two spinal taps, labs, tests, and finally arteriography found Fibromuscular dysplasia (FMD).  FMD is a disease that causes one or more arteries in the body to have abnormal cell development in the artery wall.  He had suffered a stroke caused by a dissection of his carotid artery.

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