340B 101The Basics - LPHIlphi.org/CMSuploads/340B-101The-Basics-98128.pdf · What is 340B? 340...
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Transcript of 340B 101The Basics - LPHIlphi.org/CMSuploads/340B-101The-Basics-98128.pdf · What is 340B? 340...
Learning Objectives
Intent of the program
1
340B Pricing determination
2
Entity eligibility
3
4 5 6
INTEGRITY ● ACCESS ● VALUE 2
Entity enrollment procedure
Program requirements
and prohibitions
Program guidanceand policy
Patient eligibility
determination
7
Drug delivery options
8
Available resources
9
What is 340B?
340 entities?
340 drugs on the formulary?
Year it was
340 pharmacies?
340 hospitals?
340 lawyers that got together
INTEGRITY ● ACCESS ● VALUE 3
Year it was created?
got together
340 manufacturers
Creation of the 340B Program
DRUG PRICING PROGRAM
340B
INTEGRITY ● ACCESS ● VALUE 4
$
Outpatient Drugs
Drug Manufacturers
Intent of the 340B Program
Safety net providers
SAVINGS
Improve financial stability
INTEGRITY ● ACCESS ● VALUE 5
Patients340B Eligible Entities
stability
Stretch dollars to serve vulnerable patients
The 340B Price
The 340B price is actually a “ceiling” price
25-50%of the average wholesale price
DRUG PRICING PROGRAM
340B
INTEGRITY ● ACCESS ● VALUE 6
Drug Manufacturers
The 340B price is actually a “ceiling” price
Can offer sub-ceiling prices
The 340B Price
The 340B price is actually a “ceiling” price
25-50%of the average wholesale price
DRUG PRICING PROGRAM
340B
INTEGRITY ● ACCESS ● VALUE 7
Centers for Medicare and Medicaid Services
Drug Manufacturers
The 340B price is actually a “ceiling” price
OFFICE OFPHARMACY AFFAIRS
340B Entity Eligibility
The eligibility to purchase at the 340B price belongs only to the entities
INTEGRITY ● ACCESS ● VALUE 8
340B Entity Eligibility
Consolidated Health Centers
Federally Qualified Health Center, or FQHC look-alikes
Family planning (Title X)
Comprehensive hemophilia diagnostic treatment centers
Native Hawaiian health centers
Urban Indian organizations
Certified tuberculosis clinics
INTEGRITY ● ACCESS ● VALUE 9
Ryan White Care Act (Parts A, B, C, D) grantees
Black lung clinics
Certified tuberculosis clinics
Certain disproportionate share hospitals (>11.75%)
Certified sexually transmitted disease clinics
340B Enrollment Procedure
ELIGIBLE ENTITIES MUST ENROLL
FORMS AND ENROLLMENT INFORMATION
Click on “Legal Resources”
http://www.hrsa.gov/opa
INTEGRITY ● ACCESS ● VALUE 10
ADMISSION PROCESS
Submit completed form to OPA
OPA verifies eligibility
Participation begins next quarterly database update
340B Enrollment Procedure
FIND THE FORM
COMPLETE THE FORM
http://www.hrsa.gov/opa/legalresources.htm
Click on “Introduction to 340B”
INTEGRITY ● ACCESS ● VALUE 11
DEADLINES
���� participation begins 1 month after the enrollment deadline
340B Statute Requirements and Prohibitions
340B Legislation
Program Components
INTEGRITY ● ACCESS ● VALUE 12
Program Components
Eligible Entities
Price Formula
Requirements & Prohibitions
340B Statute Requirements and Prohibitions
INTEGRITY ● ACCESS ● VALUE 13
Audit Resell/Transfer
Prohibition
Duplicate Discount
Prohibition
Prime Vendor DisproportionateShare Hospital
GPO Exclusion
340B Regulation and Policy
Interpreting the legislation and
implementing the 340B Program
may at times be a challenge
INTEGRITY ● ACCESS ● VALUE 14
Federal Register Notice publication
www.hrsa.gov/opa
OFFICE OFPHARMACY AFFAIRS
340B Regulation and Policy
Definition
entity has established relationship & maintains records of care
1
3 patient receives health care consistent with
2 patient receives health care services from health care professional employed/contracted with entity
INTEGRITY ● ACCESS ● VALUE 15
Federal Register Notice publication
www.hrsa.gov/opa/federalregister.htm
OFFICE OFPHARMACY AFFAIRS
Definition of a Patient
3 patient receives health care consistent with range of services from the covered entity
340B Regulation and Policy
Definition
If three requirements are not met, the person is not eligible for 340B drugs
INTEGRITY ● ACCESS ● VALUE 16
Federal Register Notice publication
www.hrsa.gov/opa/federalregister.htm
OFFICE OFPHARMACY AFFAIRS
Definition of a Patient
340B Implementation Options
340B Eligible Entities
Entities expressed
interest in new ways
to increase access to
INTEGRITY ● ACCESS ● VALUE 17
to increase access to
340B drugs
340B Implementation Options
340B Eligible Entities
OFFICE OFPHARMACY AFFAIRS
INTEGRITY ● ACCESS ● VALUE 18
Alternative Methods Demonstration Projects
www.hrsa.gov/opa/alternativemethods.htm
Integrity Resource:
Develops innovative pharmacy
service models
Serves as Federal resource for pharmacy
Administers 340B program
Office of Pharmacy Affairs (OPA)
INTEGRITY ● ACCESS ● VALUE 20
Integrity
service models and supports technical assistance
for pharmacy practice
340B program
• Access to affordable drugs
• Application of “best practices”
• Efficient pharmacy management
• Systems to improve patient outcome
Importance of Comprehensive Pharmacy Services
Access Resource:
Helps eligible entities,
implement and
Providesinformation resources,
Pharmacy Services Support Center (PSSC)
INTEGRITY ● ACCESS ● VALUE 21
implement and optimize the 340B program
resources,policy analysis &
education
Access
• Call Center
• Web Site
• Outreach Program
• Pharmacy Technical Assistance Program
Operates
Value Resource:
Offers value added products and services
Negotiates sub-ceiling prices
Helps with access to drug
Prime Vendor Program (PVP)
INTEGRITY ● ACCESS ● VALUE 22
Offered at no cost to entity
Helps with access to drug distribution solutions
Value
Staying connected to the 340B World
ASHP meetings
June and December
APHA meeting
April
340B Coalition meetings
SNHPA http://www.safetynetrx.org
HRSA http://www.hrsa.gov/opa/
PSSC http://pssc.aphanet.org/
INTEGRITY ● ACCESS ● VALUE 23
340B Coalition meetings
January and July
APhA Pharmacy Today
Access For All
Network at various entity specific meetings
(NACHC, NAPH, Primary Care Associations,etc.)
http://pssc.aphanet.org/
Prime Vendor Program http://340bpvp.com
The Monitor
List Serves
Others…
Contacts:
www.hrsa.gov/opa
1-800-628-6297
OFFICE OFPHARMACY AFFAIRS
Pharmacy Services
INTEGRITY ● ACCESS ● VALUE 24
pssc.aphanet.org
www.340bpvp.com
1-888-340-2787
Pharmacy Services Support Center
Prime Vendor Program