CPAs and ADVISORS. experience access // 340B QUALIFICATIONS, BENEFITS AND CURRENT FOCUS
|
|
- Barbra Heath
- 8 years ago
- Views:
Transcription
1 CPAs and ADVISORS experience access // 340B QUALIFICATIONS, BENEFITS AND CURRENT FOCUS BRIAN M. BELL BRAD K. BROTHERTON DIRECTOR PARTNER
2 MATERIALS COVERED TODAY 340B Program Evolution, Purpose & Benefits HRSA & Manufacturer Audits Omnibus Guidance (Mega Guidance) Compliance Environment 340B: Seven Key Compliance Areas Independent Audits 2 // experience access
3 THE EVOLUTION OF 340B 340B was started with the Public Health Services Act Audit guidelines established. Patient definition clarified. Contract pharmacy process established. HRSA guidance on contract pharmacies allowing multiple relationships. ACA expands eligibility to include 5 new entities HRSA begins audits and Recertification process established Federal judge invalidates HRSA s orphan drug regulation Guidance on outpatient clinics released by HRSA Medicaid duplicate discount prohibition Carve-in/Carve-out On August 28, 2015, HRSA released 340B Omnibus Guidance (Mega Guidance) Orphan drug exclusion 2015 Future GPO prohibition guidance HRSA issues final rule on orphan drug exclusion Compliance Independent Audits Quarterly Auditable Records 3 // experience access
4 340B PROGRAM OVERVIEW PURPOSE Federally mandated drug pricing program Part of Public Health Service Act, section 340B and Medicaid rebate program Drug Manufacturers must provide front-end discounts on covered outpatient drugs purchased by covered entities Provides discounts on outpatient drugs purchased by safety net providers for eligible patients Intended to provide financial relief to those facilities that provide care to the medically underserved Average savings of 25-50% for eligible covered entities on outpatient drugs Purpose of savings: Provide discounts on drugs to patients Expand services by provider to patients Provide services to more patients 4 // experience access
5 5 // experience access HRSA and Manufacturer Compliance Activities
6 340B CONTINUUM EDUCATION EXPANSION COMPLIANCE // experience access
7 COMPLIANCE ENVIRONMENT HRSA AUDITS AS OF 2012 audits 51 now publicly available & final 26 have public letters to manufacturers 18 had no adverse findings 2013 audits 93 now publicly available 59 have sanctions of repayment to manufacturers 21 had no adverse findings 2014 audits 95 now publicly available 60 have sanctions of repayments to manufacturers 19 had no adverse findings 7 // experience access
8 COMPLIANCE ENVIRONMENT HRSA AUDITS 2015 AND BEYOND 2015 audits 86 now publicly available & final 46 have public letters to manufacturers 23 had no adverse findings Audits initially had a collaborative/educational tone but the tone has changed when HRSA began instituting punitive penalties to ensure compliance $6 million in new funding for program integrity efforts approved as part of the 2014 Omnibus spending bill OPA expects to perform twice as many audits in FY 2015 as it did in FY 2014 HRSA will continue to focus on contract pharmacy arrangements, diversion, duplicate discounts and 340B database records 8 // experience access
9 2012 Through 2015 Published Audit Results Contract Pharmacy Oversight 5% Drugs Dispensed to Ineligible Individuals 45% Billing Contrary to the Medicaid Exclusion File 26% Incorrect Database Records 46% 0% 10% 20% 30% 40% 50% Source: Review of Published Audit Results on HRSA website 9 // experience access
10 MANUFACTURER AUDITS Manufacturer Audit Guidelines May only conduct after showing of reasonable cause Manufacturer inquiries to covered entity may help support reasonable cause Important for covered entities to respond to manufacturer inquiries, failure to respond could result in audit Details are not publicly available 10 // experience access
11 GROSS PROFIT MARGINS OF DRUG AND BIOTECH COMPANIES Q // experience access
12 Omnibus Guidance (Mega Guidance) 12 // experience access
13 TIMELINE AND PROCESS August 28, 2015 Proposed guidance released by HRSA October 27, 2015 Comments on the proposed guidance are due Not formal rulemaking, HRSA has requested comments before the proposed guidance is finalized 340B Health, Pharmaceutical Research and Manufacturers of American, American Hospital Association and National Associations of Community Health Centers will submit comments BKD will submit comments It is critical that covered entities submit comments to ensure HRSA understands the potential impact of the proposed guidance Covered entities should be preparing to evaluate impact when finalized 13 // experience access
14 GPO EXCLUSION CLARIFICATION For hospitals enrolled as DSH, children s hospital or freestanding cancer hospital This clarification extends and prohibits the use of a GPO to any pharmacy owned or operated by a DSH covered entity If a covered entity purchases from GPO as a last resort and documents appropriately, the covered entity will not be considered in violation of GPO exclusion Extremely important due to drug shortages The prime vendor program is not considered a GPO subject to this prohibition 14 // experience access
15 PATIENT DEFINITION Service provided in a location that is not listed in the 340B database is not considered an eligible location Ensuring child sites are registered will continue to be a critical compliance element An individual is not considered a patient of the covered entity if his or her care is classified as inpatient and billed as inpatient Historically patient who was in ER, observation or other OP area and was later admitted as an inpatient was eligible for 340B drugs up to the time of admission Would further implications for entities subject to 3 day window Prescriptions written as part of an inpatient stay (discharge prescriptions) often filled under meds-to-beds program or subsequently through contract pharmacy relationships are not longer considered 340B eligible dispensations within contract pharmacy arrangements 15 // experience access
16 PATIENT DEFINITION An individual who receives follow-up care at a private practice (noncovered entity) location is not eligible to receive 340B drugs Individual must receive health care services from a provider who is either employed by or is an independent contractor of the covered entity such that the covered entity may bill for services on behalf of the provider. Previously HRSA required that the provided by employed by, contracted or other arrangements (referral for consultation) with the covered entity Physician privileges or credentials at a covered entity is not sufficient to demonstrate an individual is a patient of the covered entity for 340B purposes Referral prescriptions will only be 340B eligible if an eligible provider has written the prescription 16 // experience access
17 MEDICAID AND MEDICAID MANAGED CARE Covered entities are now able to make a determination for both Medicaid Fee for Service and Medicaid Managed Care Organizations when determining to carve in or carve out Medicaid Prevention of duplicate discounts remains the requirement of the covered entity Critical for covered entity to maintain dialogue with state Medicaid agencies to prevent duplicate discounts 17 // experience access
18 CONTRACT PHARMACY ARRANGEMENTS HRSA defines a contract pharmacy as a pharmacy that is not covered by the covered entity Could threaten existing contract pharmacy arrangements involving pharmacies that are not legally separate from covered entity Under contract pharmacy arrangements, both Medicaid FFS and Medicaid MCO dispensations will be excluded from the 340B Drug Program unless a well-documented plan from the covered entity, managed care company and state Medicaid agency clearly states how duplicate discounts will be mitigated 18 // experience access
19 INDEPENDENT AUDIT EXPECTATION Mega Guidance emphasizes the continued importance and expectation of an annual independent audit being perform HRSA is proposing standards for audit and quarterly review of contract pharmacy arrangements to ensure that compliance efforts result in Early identification of problems Implementation of corrections Prevention of future compliance issues Maintain auditable data for a period of not less than 5 years 19 // experience access
20 INDEPENDENT AUDITS HRSA S VIEW HRSA believes that covered entities that do not regularly review and audit contract pharmacy operations are at increased risk for compliance issues Annual audit of each location will provide covered entities: Regular opportunity to review and reconcile 340B patient eligibility information Prevent diversion Covered entity should compare 340B prescribing records with contract pharmacy s dispensing records at least on a quarterly basis to prevent: Diversion Duplicate discounts Conducting these audits using an independent auditor will ensure the pharmacy is following all 340B program requirements and provide the covered entity with ability to timely report any violations if applicable 20 // experience access
21 21 // experience access Compliance Environment
22 SEVEN KEY COMPLIANCE AREAS Eligibility Diversion Contract Pharmacy Orphan Drugs Registration Duplicate Discounts Group Purchasing Organization 22 // experience access
23 WHAT ARE YOUR TOP RISKS RELATED TO 340B? Do you know what your top risks are? Do your risks include all your registered sites, contracting pharmacies, etc.? How do you plan to minimize these risks? How will these risks be identified? 23 // experience access
24 COMPLIANCE REGISTRATION Registration Covered entity must register with HRSA Each eligible entity location that plans to use 340B drugs (clinic or offsite outpatient department) must be separately registered Information should be collected by the authorizing official during the annual recertification process 24 // experience access
25 COMPLIANCE REGISTRATION Recertification process for all covered entity types is required annually or covered entity will be removed from the Program Authorizing official must attest to eight statements 8 25 // experience access
26 COMPLIANCE RECERTIFICATION PROCESS 1. All information listed on the 340B Program database for the covered entity is complete, accurate & correct; 2. The covered entity meets all 340B Program eligibility requirements 3. The covered entity is complying with all requirements & restrictions of Section 340B of the Public Health Service Act IS YOUR AUTHORIZING OFFICIAL READY TO ATTEST TO THESE 3 QUESTIONS? 26 // experience access
27 COMPLIANCE DIVERSION Diversion Drugs can only be used on an outpatient basis for covered entity s patients as defined by HRSA Use for other individuals constitutes prohibited diversion Focus on defining patient & covered entity What is covered entity? Where services are provided Physicians must be employed or under a contractual or other arrangement Entity should have a listing of approved 340B physicians 27 // experience access
28 COMPLIANCE DUPLICATE DISCOUNTS Duplicate discounts 340B laws prohibit application of both 340B price discount (front end) and payment of pharmacy rebate to state Medicaid (back end) on same drug claim General options for covered entities Carve-out Medicaid - from 340B drug purchases Carve-in Medicaid - requires verifying Medicaid exclusion file is accurate Medicaid managed care 28 // experience access
29 COMPLIANCE DUPLICATE DISCOUNTS Medicaid duplicate discount Some states have been slow to establish and communicate Medicaid billing requirements and potential modifiers Transition to Medicaid managed care has created confusion Contract pharmacies should not Carve-in unless arrangement with state Medicaid exists Recommendation Engage in ongoing dialogue with Medicaid pharmacy directors of the states where you file claims a winwin solution may be available THE RESPONSIBILITY FOR AVOIDING DUPLICATE DISCOUNTS IS ON THE COVERED ENTITY!! 29 // experience access
30 COMPLIANCE CONTRACT PHARMACY Contract Pharmacy HRSA allows providers to enter into arrangements with multiple contract pharmacies to dispense 340B drugs to qualifying patients of providers Covered entity is responsible for compliance & must monitor contract pharmacies HRSA recommends independent audits 30 // experience access
31 COMPLIANCE REPORT CONTRACT PHARMACY OIG on Contract Pharmacy Arrangements in the 340B Program February 2014 Memorandum Report: Contract Pharmacy Arrangements in 340B Program, OEI Report stated that it creates complications in preventing diversion & duplicate discounts Report noted that some covered entities do not: 1. Offer 340B discounts to uninsured patients at their contracted pharmacies 2. Provide sufficient oversight of contract pharmacies 3. Many do not engage outside independent auditors to review them 31 // experience access
32 COMPLIANCE GROUP PURCHASING ORGANIZATION GPO Restriction: Certain hospitals (acute care with DSH > 11.75%, children s, cancer) may not purchase any covered outpatient drugs through GPO. Inpatient drugs may be purchased through a GPO. Hospitals may purchase outpatient drugs through the Prime Vendor Program (APEXUS). The GPO Prohibition pertains to: Disproportionate Share Hospitals Pediatric Hospitals Cancer Centers Drug purchases through GPO (Group Purchasing Organization) contracts cannot be used for outpatients covered by 340B 32 // experience access
33 COMPLIANCE- ORPHAN DRUG RULES Orphan drug rule is applicable to covered entities participating as SCH, RRC, CAH and free-standing cancer hospitals Since 2010, these types of covered entities have been unable to purchase orphan drugs at 340B price, regardless of illness the drug was prescribed to treat July 23, Health Resources Services Administration (HRSA) published long-awaited final regulations on orphan drugs May 23, Federal Judge invalidates 340B orphan drug regulation July 21, 2014 Interpretive Rule issued which does not exclude use of drugs for conditions or diseases other than the orphan designation October 9, 2014 PhRMA filed lawsuit in federal court against interpretation 33 // experience access
34 COMPLIANCE- ORPHAN DRUG RULES January 2015 HHS files motion for summary judgment Potential compliance concerns or issues if 340B-covered entity uses orphan drugs within 340B-eligible patients Development of auditable tracking system How to ensure prescriptions filled at covered entity s retail pharmacy or through contract pharmacy were not related to treatment of the rare disease (is an eligible dispensation) 34 // experience access
35 COMPLIANCE CONSEQUENCES OF NOT COMPLYING Repayment of discount to manufacturer Removal from 340B Program Possible Civil Monetary Penalties for knowing & intentional violations Potentially false claim liability (ripe for qui tam actions?) 35 // experience access
36 RESOURCES Resource HRSA OPA About 340B Program Audits of Covered Entity Policy Releases OPA FAQs HRSA 340B Peer-to-Peer Webinars 340B Prime Vendor Program 340B Prime Vendor Program FAQs Description HRSA Office of Pharmacy Affairs homepage HRSA Program Integrity Page HRSA Policy releases regarding the 340B Drug Pricing Program HRSA Office of Pharmacy Affairs Frequently Asked Questions (FAQs) Register for upcoming 340B Peer-to-Peer Webinars and listen to past webinars Call Center Phone: Web: Prime Vendor Program Frequently Asked Questions (FAQs) 36 // experience access
37 THANK YOU FOR MORE INFORMATION // For a complete list of our offices and subsidiaries, visit bkd.com or contact: Brian M. Bell// Director bbell@bkd.com // Brad K. Brotherton// Partner bbrotherton@bkd.com //
340B: ARE WE MONITORING COMPLIANCE EFFECTIVELY AND EFFICIENTLY
CPAs & ADVISORS experience clarity // 340B: ARE WE MONITORING COMPLIANCE EFFECTIVELY AND EFFICIENTLY September 17, 2014 Michael Earls, CPA, Senior Manager September 17, 2014 OVERVIEW OF TODAY S PRESENTATION
More information10/1/2013. Objectives. 340B Drug Pricing Program; Transitioning from Access to Integrity. 340B Stats, Arkansas. 340B Participating Entities, AR
Objectives Drug Pricing Program; Transitioning from Access to Integrity Arkansas Association of Health-system Pharmacists 47 th Annual Fall Seminar October 3 & 4, 2013 Chris Hatwig RPh, MS, FASHP President,
More information340B Drug Discount Program Improving Compliance to Protect Savings and Be Audit Ready. Suzanne Herzog Founding Director Rx X Consulting
340B Drug Discount Program Improving Compliance to Protect Savings and Be Audit Ready Suzanne Herzog Founding Director Rx X Consulting What is 340B? 340B Overview A drug discount program that allows covered
More informationMega Guidance Is Here!
Mega Guidance Is Here! David Pointer has no actual or potential conflict of interest in relation to this presentation. 1 Introduction Where are we today? Brief Overview of HRSA Audit Findings Where are
More informationMega Guidance Is Here!
Mega Guidance Is Here! David Pointer has no actual or potential conflict of interest in relation to this presentation. Introduction Where are we today? Brief Overview of HRSA Audit Findings Where are we
More informationFinally... maybe? The Long Awaited 340B Mega Guidance. Georgia Healthcare Financial Management Association. October 2015
Finally... maybe? The Long Awaited 340B Mega Guidance Georgia Healthcare Financial Management Association October 2015 Disclaimer This webinar assumes the participant is familiar with the basic operations
More informationFederal 340B Drug Pricing Program
2015 CliftonLarsonAllen LLP Federal 340B Drug Pricing Program March 6, 2015 Continuous learning in action Learning Objectives Explain the intent of the Federal 340B Drug Pricing Program List the eligibility
More information340B Compliance: I sure wish I d known that!
340B Compliance: I sure wish I d known that! Aaron K. Lott Pharm. D. Executive Director of Pharmacy Services June 2015 Disclosures The presenter has no significant financial or commercial interests to
More information340B Drug Discount Program Identifying risks and internal audit focus areas
340B Drug Discount Program Identifying risks and internal audit focus areas Introduction The 340B Drug Discount Program is administered by the Health Resources and Services Administration (HRSA) Office
More information340B Drug Pricing Program: Recent Developments and Compliance Update
340B Drug Pricing Program: Recent Developments and Compliance Update Elizabeth S. Elson, Esq. Anil Shankar, Esq. November 19, 2015 Attorney Advertising Prior results do not guarantee a similar outcome
More information340B Drug Discount Program Overview and Emerging Issues
340B Drug Discount Program Overview and Emerging Issues I. APPLICABLE STATUTE AND OTHER LEGAL AUTHORITIES Section 340B of the Public Health Service Act (42 U.S.C. 256b) requires pharmaceutical manufacturers,
More information340B Drug Pricing Program: Overview and Recent Developments
340B Drug Pricing Program: Overview and Recent Developments November 12, 2015 Kirstin B. Ives Partner and Chair of Healthcare Litigation Group Williams Montgomery & John Ltd. 233 S. Wacker Drive, Suite
More informationThe 340B Drug Discount Program Overview, Compliance Issues and Interplay with Medicare and Medicaid
The Drug Discount Program Overview, Compliance Issues and Interplay with Medicare and Medicaid Barbara Straub Williams Powers Pyles Sutter & Verville PC American Health Lawyers Association 2014 Institute
More informationXXXXXXXFUNDAMENTALS An Essential Guide for Health System Executive Management
340B XXXXXXXFUNDAMENTALS An Essential Guide for Health System Executive Management 800.473.3516 www.wellpartner.com Table of Contents 340B Fundamentals for Health System Executive Management...1 What
More informationLegal Alert. Long-Awaited 340B Program Guidance Now Available for Comments: What Stakeholders Need to Know. Authors
September 10, 2015 1 Legal Alert Authors Stephanie Trunk Partner stephanie.trunk@arentfox.com Erin E. Atkins Associate erin.atkins@arentfox.com Long-Awaited 340B Program Guidance Now Available for Comments:
More informationA fter much-anticipation, the Health Resources and
BNA s Health Care Policy Report Reproduced with permission from BNA s Health Care Policy Report, 23 HCPR 1420, 09/21/2015. Copyright 2015 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com
More informationASHP Regulatory Alert
Proposed Guidance: 340B Drug Discount Program Introduction On Friday, August 28, 2015, the Health Resources and Services Administration (HRSA) published the long awaited proposed omnibus guidance for the
More informationKeep Your Savings: 340B Audits and Ensuring Compliance
Keep Your Savings: 340B Audits and Ensuring Compliance Disclosure This presentation reflects experience with the topics at hand and does not constitute legal advice, and does not reflect interpretation
More informationO n Aug. 28, the Department of Health and Human
BNA s Health Law Reporter Reproduced with permission from BNA s Health Law Reporter, 24 HLR 1202, 9/17/15. Copyright 2015 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com HRSA
More information340B Drug Pricing Program
340B Drug Pricing Program Chad E. Gay Director of Contract Compliance Agenda Discuss the 340B drug pricing program How the program is defined Who is eligible Enrollment Dates to be aware of Source Documentation
More information340B Mega Guidance: Implications for Essential Hospitals Sarah Mutinsky and Barbara Eyman Washington Counsel, America s Essential Hospitals Eyman
340B Mega Guidance: Implications for Essential Hospitals Sarah Mutinsky and Barbara Eyman Washington Counsel, America s Essential Hospitals Eyman Associates September 10, 2015 TODAY S AGENDA Background
More informationThe 340B Program: New Developments and New Opportunities for CAHs and Others. Todd Nova Hall Render
The 340B Program: New Developments and New Opportunities for CAHs and Others Todd Nova Hall Render Wisconsin Office of Rural Health Hospital Finance Workshop August 30, 2011 What We Will Cover 2 340B Program
More information340B Drug Pricing Program. A Survey of the Program s Past, Present, and Future
340B Drug Pricing Program A Survey of the Program s Past, Present, and Future Presented by: Daniel Soldato Wyatt, Tarrant & Combs LLP dsoldato@wyattfirm.com (859) 288-7631 Disclaimer The views expressed
More informationSpeakers. Recent Developments in 340B Drug Pricing Program Compliance and Enforcement. Elizabeth S. Elson, Esq. Anil Shankar, Esq.
1 Recent Developments in 340B Drug Pricing Program Compliance and Enforcement Elizabeth S. Elson, Esq. Anil Shankar, Esq. October 18, 2012 2 Speakers Elizabeth Elson Of Counsel Foley & Lardner LLP Los
More information340B Drug Pricing Program January 15, 2015
340B Drug Pricing Program January 15, 2015 340B Basics - Gary Merchant. MBA, BSPharm 340B Audit - Robert Theriault, MBA, BSPharm Declarations Neither Gary Merchant nor Robert Theriault have no actual or
More information4/3/2015 WHAT IS 340B? DISCLOSURE. No conflicts of interest to disclose
WHAT IS 340B? S C O T T M I L N E R P H AR M D, M B A DISCLOSURE No conflicts of interest to disclose 1 OBJECTIVES At the end of this presentation we should be able to: Describe the origin of the 340b
More informationOctober 27, 2015. Attention: RIN 0906-AB08. RE: 340B Drug Pricing Program Omnibus Guidance. Dear Captain Pedley:
Captain Krista Pedley, Director Office of Pharmacy Affairs Health Resources and Services Administration 5600 Fishers Lane Mail Stop 08W05A Rockville, MD 20857 Attention: RIN 0906-AB08 RE: 340B Drug Pricing
More information340B Integrity Audit: Is Your Hospital Ready for a HRSA Audit? February 4, 2013
340B Integrity Audit: Is Your Hospital Ready for a HRSA Audit? February 4, 2013 1 Agenda 340B Program Overview Why HRSA Audits? What will HRSA Audits Cover? Verification of Eligibility: Covered Entity,
More informationThe 3 Keys to Success in Your 340B Program. Rob Nahoopii, PharmD, MS, BCPS CEO Turnkey Pharmacy Solutions A 340B Management Company
The 3 Keys to Success in Your 340B Program Rob Nahoopii, PharmD, MS, BCPS CEO Turnkey Pharmacy Solutions A 340B Management Company Objectives Provide a description and overview of the 340B program Discuss
More information2015-340B & Prime Vendor Program Update
2015-340B & Prime Vendor Program Update Christopher A. Hatwig, R.Ph., MS, FASHP President, Apexus 340B Sales by Entity Types Percentage of Total Apexus Participant Sales 90.00% 80.00% 70.00% 60.00% 50.00%
More informationSUMMARY OF HRSA PROPOSED OMNIBUS GUIDANCE ON THE 340B DRUG DISCOUNT PROGRAM
L A W O F F I C E S HYMAN, PHELPS & MCNAMARA, P.C. 7 0 0 T H I R T E E N T H S T R E E T, N. W. S U I T E 1 2 0 0 W A S H I N G T O N, D. C. 2 0 0 0 5-5 9 2 9 ( 2 0 2 ) 7 3 7-5 6 0 0 F A C S I M I L E
More information340B Drug Discount Program 2013 March 15, 2013 1 Agenda 340B Program Overview Covered Entities Covered Drugs Covered Patients Why HRSA Audits How to Prepare for HRSA Audit Questions/Answers 2 340 DRUG
More information340B PROGRAM. Scrutiny & Uncertainty Increase the Need for Compliance
340B PROGRAM Scrutiny & Uncertainty Increase the Need for Compliance Uncertainty will always be part of the taking charge process. Harold S. Geneen For many years, drug manufacturers and Covered Entities
More informationOctober 9, 2015. RIN 0906-AB08 340B Drug Pricing Program Omnibus Guidance. Dear Director Pedley:
October 9, 2015 Krista Pedley Director, Office of Pharmacy Affairs Health Resources and Services Administration 5600 Fishers Lane Mail Stop 08W05A Rockville, Maryland 20857 Re: RIN 0906-AB08 340B Drug
More informationHRSA Issues 340B Program Omnibus Guidance
3 September 2015 Practice Groups: Healthcare FDA HRSA Issues 340B Program Omnibus Guidance By Gina L. Bertolini, Richard P. Church, Leah D'Aurora Richardson On August 28, 2015, the Health Resources and
More informationHHS Releases Long-Awaited 340B Proposed Guidance
AUGUST 31, 2015 HHS Releases Long-Awaited 340B Proposed Guidance David Ivill, Emily Cook and Joseph Parise On August 27, 2015, the U.S. Department of Health and Human Services (HHS) released the long-awaited
More informationOPA DATABASE GUIDE PUBLIC USERS - RECERTIFICATION FOR AUGUST 2013 VERSION 5.2.1
OPA DATABASE GUIDE FOR PUBLIC USERS - RECERTIFICATION AUGUST 2013 VERSION 5.2.1 CERTIFICATION 1 Authorizing Official (AO) Advance Notification 1 340B Recertification Email 2 AO Logging In 3 Navigating
More informationDSH Litigation and 340B Program Update: What Participating Hospitals Need to Know and What They Should Be Doing
DSH Litigation and 340B Program Update: What Participating Hospitals Need to Know and What They Should Be Doing Presented by: Joe Metro, Partner Sal Rotella, Partner Agenda Disproportionate Share Hospital
More information340B DRUG DISCOUNT PROGRAM OMNIBUS GUIDANCE. Presented by the American Bar Association Health Law Section and Center for Professional Development
340B DRUG DISCOUNT PROGRAM OMNIBUS GUIDANCE Presented by the American Bar Association Health Law Section and Center for Professional Development American Bar Association Center for Professional Development
More information340B Omnibus Guidance Would Significantly Narrow the Pool of Eligible Patients
White Paper August 31, 2015 340B Omnibus Guidance Would Significantly Narrow the Pool of Eligible Patients By Kristi V. Kung This client alert also was published as a bylined article on Law360 on September
More information340B Drug Pricing Program 340B Contract Pharmacy
340B Drug Pricing Program 340B Contract Pharmacy LTJG Enudio Mercado-Gonzalez, USPHS Program Management Officer U.S. Department of Health and Human Services Health Resources and Services Administration
More information340B Policy Landscape
340B Policy Landscape Providence 2015 340B Summit Presented by Steve Brennan, Director, Public Policy Providence Health & Services Sept. 28, 2015 1 Today s topics Backdrop of debate over 340B program Legislative
More information(RIN) 0906-AB08; 340-B
October, 2015 Ms. Krista Pedley Director, Office of Pharmacy Affairs (OPA) Health Resources and Services Administration (HRSA) 5600 Fishers Lane, Mail Stop 08W05A Rockville, Maryland 20857 Re: Regulatory
More informationStructuring 340B Contract Pharmacy Arrangements: Meeting Legal and Regulatory Requirements
Presenting a live 90-minute webinar with interactive Q&A Structuring 340B Contract Pharmacy Arrangements: Meeting Legal and Regulatory Requirements THURSDAY, JUNE 4, 2015 1pm Eastern 12pm Central 11am
More informationOverview of the 340B Drug Pricing Program
M a y 2 0 1 5 Report to the Congress Overview of the 340B Drug Pricing Program M a y 2 0 1 5 Report to the Congress Overview of the 340B Drug Pricing Program 425 I Street, NW Suite 701 Washington, DC 20001
More informationSec. 340B PUBLIC HEALTH SERVICE ACT
Sec. 340B PUBLIC HEALTH SERVICE ACT LIMITATION ON PRICES OF DRUGS PURCHASED BY COVERED ENTITIES (a) REQUIREMENTS FOR AGREEMENT WITH SECRETARY. (1) IN GENERAL. The Secretary shall enter into an agreement
More informationDisclosure. Overview. Safety Net Hospitals for Pharmaceutical Access
340B: Issues and Opportunities in Pharmacy Automation Safety Net Hospitals for Pharmaceutical Access Executive Director, SNHPA Editor in Chief, Drug Discount Monitor American Society for Automation in
More informationSTATEMENT OF DIANA ESPINOSA DEPUTY ADMINISTRATOR, HEALTH RESOURCES AND SERVICES ADMINISTRATION BEFORE THE
STATEMENT OF DIANA ESPINOSA DEPUTY ADMINISTRATOR, HEALTH RESOURCES AND SERVICES ADMINISTRATION BEFORE THE U.S. HOUSE ENERGY AND COMMERCE COMMITTEE SUBCOMMITEE ON HEALTH WASHINGTON, D.C. MARCH 5, 2015 Good
More informationHRSA Pharmacy Services Support Center: The 340B Access Resource
HRSA Pharmacy Services Support Center: The 340B Access Resource Lisa Scholz PharmD, MBA Vice President, APhA HRSA Pharmacy Services Support Center Office of Population Affairs Webinar 9/16 INTEGRITY ACCESS
More informationThe 340B Drug Pricing Program. Ariel Winter and Daniel Zabinski November 6, 2014
The 340B Drug Pricing Program Ariel Winter and Daniel Zabinski November 6, 2014 Outline Background on 340B program Program has grown substantially 340B statute does not define key terms, allows many providers
More informationExpanding 340B Participation: The Provider-Based Challenge
Expanding 340B Participation: The Provider-Based Challenge Presentation by Karen Smith, Esq. & David Johnston, Esq. Bricker & Eckler LLP www.bricker.com Columbus l Cleveland l Cincinnati-Dayton I Marietta
More informationDate: September 3, 2014
Date: September 3, 2014 Subject: Background on Sections 401 and 403 of the Indian Health Care Improvement Act: Disregarding Certain Payments in Determining Appropriations and Reporting Requirements Note:
More information340B Program New Developments and Increasing Scrutiny
340B Program New Developments and Increasing Scrutiny Todd Nova Hall Render tnova@hallrender.com Wisconsin Office of Rural Health Hospital Finance Workshop August 24, 2012 What We Will Cover 2 340B Program
More informationThe Pharmacy 340B Program- Compliance & Internal Audit Strategies. for Covered Entities. Matthew D. Vogelien Huron Healthcare
The Pharmacy 340B Program- Compliance & Internal Audit Strategies Matthew D. Vogelien Huron Healthcare for Covered Entities 340B Drug Discount Program (340B Program) Discussion Outline Topics for Discussion:
More informationNAMD WORKING PAPER SERIES. Medicaid and the 340B Program: Alignment and Modernization Opportunities
NAMD WORKING PAPER SERIES Medicaid and the 340B Program: Alignment and Modernization Opportunities May 2015 444 North Capitol Street, Suite 524 Washington, DC 20001 Phone: 202.403.8620 www.medicaiddirectors.org
More informationHRSA Issues Proposed Omnibus 340B Guidance
HRSA Issues Proposed Omnibus 340B Guidance September 2015 1 HRSA Issues Proposed Omnibus 340B Guidance John Gould, Jeffrey L. Handwerker, Rosemary Maxwell, Matthew T. Fornataro, Kristin M. Hicks, Rahul
More informationOctober 27, 2015. Krista Pedley, Director Office of Pharmacy Affairs Health Resources and Services Administration.
1015 15 th Street, N.W., Suite 950 Washington, DC 20005 Tel. 202.204.7508 Fax 202.204.7517 www.communityplans.net John Lovelace, Chairman Margaret A. Murray, Chief Executive Officer October 27, 2015 Krista
More informationGAO DRUG PRICING. Manufacturer Discounts in the 340B Program Offer Benefits, but Federal Oversight Needs Improvement
GAO United States Government Accountability Office Report to Congressional Committees September 2011 DRUG PRICING Manufacturer Discounts in the 340B Program Offer Benefits, but Federal Oversight Needs
More information340B University Page 1 Split-Billing Software Considerations Checklist
340B University Page 1 Purpose: The purpose of this tool is to provide a decision checklist for entities to evaluate split-billing software. The tool presents considerations for an entity when selecting,
More informationThe 340B Program: Today and Beyond
FL Regional Education Session - Tampa The 340B Program: Today and Beyond May 19, 2015 2:15-3:15 PM ET 2015 Safety Net Hospitals for Pharmaceutical Access 1 Disclaimer This presentation is not to be construed
More informationTEXAS VENDOR DRUG PROGRAM PHARMACY PROVIDER PROCEDURE MANUAL
1 OF 10 DOCUMENT HISTORY LOG STATUS REVISION EFFECTIVE DESCRIPTION Revision 1.1 Sep. 1, 2015 Baseline 1.0 Feb. 1, 2015 3.1 Eligible Entity 5 CAD Claim Submission o Instruction update and email address.
More informationSUMMARY: The Health Resources and Services Administration (HRSA) administers section
This document is scheduled to be published in the Federal Register on 08/28/2015 and available online at http://federalregister.gov/a/2015-21246, and on FDsys.gov Billing Code: 4165-15 DEPARTMENT OF HEALTH
More informationGROWTH OF THE 340B PROGRAM: PAST TRENDS, FUTURE PROJECTIONS
: PAST TRENDS, FUTURE PROJECTIONS Healthcare WHITE PAPER NOVEMBER 2014 Prepared By: Aaron Vandervelde avandervelde@thinkbrg.com 202.480.2661 Copyright 2014 by Berkeley Research Group, LLC. Except as may
More information7/16/2010. 14 th Annual 340B Coalition Conference July 19, 2010 Washington, DC. Safety Net Hospitals for Pharmaceutical Access
Safety Net Hospitals for Pharmaceutical Access The Story From Washington, D.C. Ted Slafsky Executive Director, SNHPA Editor in Chief, Drug Discount Monitor (202)552-58605860 ted.slafsky@snhpa.org 14 th
More informationIs your organization 340B equipped? Understanding Contract Pharmacy arrangements
Is your organization 340B equipped? Understanding Contract Pharmacy arrangements In today s era of healthcare reform that emphasizes enhanced accessibility and cost reductions, the 340B program remains
More information340B GROWTH AND THE IMPACT ON THE ONCOLOGY MARKETPLACE
340B GROWTH AND THE IMPACT ON THE ONCOLOGY MARKETPLACE Healthcare WHITE PAPER SEPTEMBER 2015 Prepared By: Aaron Vandervelde avanvervelde@thinkbrg.com 202.480.2661 Copyright 2015 by Berkeley Research Group,
More information340B University Page 1 340B Manager and Coordinator Job Description Template
340B University Page 1 Purpose: The purpose of this tool is to provide a list of activities commonly assigned to the role of 340B Manager or Coordinator. This list is not exhaustive, rather a compilation
More informationDEPARTMENT OF HEALTH AND HUMAN SERVICES Health Resources and Services Administration RIN 0906-AB08 340B Drug Pricing Program Omnibus Guidance
Page 1 THOT Members AUSTIN Central Health Seton Healthcare Family CORPUS CHRISTI CHRISTUS Spohn Health System Nueces County Hospital District DALLAS Children s Health System of Texas Parkland Health &
More informationHRSA Publishes 340B Drug Pricing Program Omnibus Guidance Notice: Significant Policy Ramifications Should Trigger Public Comment
Alert Life Sciences Health Industry If you have questions or would like additional information on the material covered in this Alert, please contact one of the attorneys listed below: Joseph W. Metro Partner,
More informationThe 340B Drug Pricing Program: The Basics
The 340B Drug Pricing Program: The Basics Paul Shank, MBA Health & Human Services Consultant, Health Resources and Services Administration Healthcare Systems Bureau, Office of Pharmacy Affairs July 14,
More informationImplementing a System-wide 340B Program
Implementing a System-wide 340B Program An Overview Steve Pitzer System Executive, Supply Chain Management CHRISTUS Health Sam Colletti, RPh Director of Enterprise Accounts- CHRISTUS Health Broadlane Objectives
More informationRE: 340B Drug Pricing Program Omnibus Guidance HRSA RIN 0906-AB08, (Vol. 80, No. 167, August 28, 2015)
October 26, 2015 Krista Pedley, PharmD, MS Captain, USPHS Director, Office of Pharmacy Affairs Health Resources and Services Administration 5600 Fishers Lane, Mail Stop 08W05A Rockville, MD 20857 Via Email:
More informationSTATES COLLECTION OF REBATES FOR DRUGS PAID THROUGH MEDICAID MANAGED CARE ORGANIZATIONS
Department of Health and Human Services OFFICE OF INSPECTOR GENERAL STATES COLLECTION OF REBATES FOR DRUGS PAID THROUGH MEDICAID MANAGED CARE ORGANIZATIONS Daniel R. Levinson Inspector General September
More information340B Compliance Self-Assessment: Self-Audit Process Page 1 A Sample Self-Audit Process for Community Health Centers
340B Compliance Self-Assessment: Self-Audit Process Page 1 Purpose: The purpose of this tool is to provide a sample internal audit process to assist participating community health center (CHC) leaders
More informationThe 340B Drug Pricing Program: The Basics INTEGRITY ACCESS VALUE 1
The 340B Drug Pricing Program: The Basics INTEGRITY ACCESS VALUE 1 Learning Objectives 1 2 3 Intent of the program 340B Pricing determination Entity eligibility 4 5 6 Program requirements and prohibitions
More informationC. Covered 340B drugs, as found in section 1927 (k)(2) of the Social Security Act, include the following outpatient drugs:
Title 23: Medicaid Part 200: General Provider Information Part 200 Chapter 4: Provider Enrollment Rule 4.10: 340B Providers A. The Division of Medicaid defines a 340B provider as a nonprofit healthcare
More informationOIG Responses to Additional Questions from Chairman Pitts Regarding the 340B Program May 4, 2015
OIG Responses to Additional Questions from Chairman Pitts Regarding the 340B Program May 4, 2015 1. HRSA had been preparing a regulation to address the definition of a patient and hospital eligibility,
More informationPrinted copies are for reference only. Please refer to the electronic copy of this policy for the latest version.
340B Pharmacy Audit Policy Version: 1.4 Date Created: 01/05/2015 Date Approved: 02/18/2015 Printed copies are for reference only. Please refer to the electronic copy of this policy for the latest version.
More informationMaximizing the 340B Drug Discount Program: A Webinar for Finance Executives in 340B Hospitals Webinar
Maximizing the 340B Drug Discount Program: A Webinar for Finance Executives in 340B Hospitals Webinar January 20, 2010 The Webinar Will Begin Momentarily National Association of Public Hospitals and Health
More informationMedicaid and 340B. Presentation to: GHA 340B Day Presented by: Linda Wiant, Pharm.D. Pharmacy Director. Date: 10-23-14 0
Medicaid and 340B Presentation to: GHA 340B Day Presented by: Linda Wiant, Pharm.D. Pharmacy Director Date: 10-23-14 0 Mission The Georgia Department of Community Health We will provide Georgians with
More informationVia Electronic Submission at http://www.regulations.gov. October 27, 2015
Via Electronic Submission at http://www.regulations.gov October 27, 2015 Krista Pedley, PharmD, MS Captain, United States Public Health Service Director, Office of Pharmacy Affairs Health Resources and
More informationAffordable Care Act Reviews
Page 66 Appendix A Affordable Care Act Reviews The Office of Inspector General (OIG) is focused on promoting the economy, efficiency, and effectiveness of Affordable Care Act 1 programs across the Department
More informationThe 340B Drug Pricing Program: The Basics
The 340B Drug Pricing Program: The Basics Todd Lemke, Pharm.D CDE Paynesville Area Health Care System Pharmacist HRSA APhA Pharmacy Services Support Center Consultant 1 Intent of the 340B Program Safety
More informationThe 340B Drug Discount Program
The 340B Drug Discount Program Ponaman Healthcare Consulting Ralph V. Moreno Jr. Presented: August 11, 2011 Table of Contents...1 THE 340B DRUG DISCOUNT PROGRAM 1.1 340B Overview......2 1.2 340B Eligibility.......
More information42 USC 256b. NB: This unofficial compilation of the U.S. Code is current as of Jan. 4, 2012 (see http://www.law.cornell.edu/uscode/uscprint.html).
TITLE 42 - THE PUBLIC HEALTH AND WELFARE CHAPTER 6A - PUBLIC HEALTH SERVICE SUBCHAPTER II - GENERAL POWERS AND DUTIES Part D - Primary Health Care subpart vii - drug pricing agreements 256b. Limitation
More informationOctober 26, 2015. Submitted electronically via http://www.regulations.gov. Re: RIN 0906-AB08; 340B Drug Pricing Program Omnibus Guidance
20555 Victor Parkway Livonia, MI 48152 tel 734-343-1000 trinity-health.org October 26, 2015 Captain Krista Pedley, PharmD, MS Director Office of Pharmacy Affairs Health Resources and Services Administration
More information340B UNIVERSITY San Francisco Edition. February 3-4, 2015
340B UNIVERSITY San Francisco Edition February 3-4, 2015 WELCOME TO 340B UNIVERSITY! About Apexus The mission of Apexus is to leverage our unique resources and expertise to deliver maximum value to 340B
More informationOREGON DID NOT BILL MANUFACTURERS FOR REBATES FOR PHYSICIAN-ADMINISTERED DRUGS DISPENSED TO ENROLLEES OF MEDICAID MANAGED-CARE ORGANIZATIONS
Department of Health and Human Services OFFICE OF INSPECTOR GENERAL OREGON DID NOT BILL MANUFACTURERS FOR REBATES FOR PHYSICIAN-ADMINISTERED DRUGS DISPENSED TO ENROLLEES OF MEDICAID MANAGED-CARE ORGANIZATIONS
More informationChallenges and Opportunities
The Future of the 340B Drug Pricing Program: Challenges and Opportunities Jeffrey R. Lewis jeffreyrobertlewis@gmail.com Mr. Lewis is the former President of PS2 Health Care and now serves as the Chief
More informationEnsuring Integrity in use of 340B pricing: Responsibility, Compliance, Accountability
Ensuring Integrity in use of 340B pricing: Responsibility, Compliance, Accountability Fern Paul-Aviles, PharmD, MS, BCPS Director, 340B and Ambulatory Regulatory Program Compliance Carolinas Healthcare
More information340B UNIVERSITY Las Vegas Edition. May 31, 2014
340B UNIVERSITY Las Vegas Edition May 31, 2014 SESSION 1: THE TOP 5: 340B BASICS FOR HOSPITALS Mike Benedict Objectives 1. Define the intent of the 340B Program 2. Describe the major 340B stakeholders
More informationHot Topics in Medicaid
Hot Topics in Medicaid Chad Hope, Pharm.D. Pharmacy Program Manager DHSS/DHCS chad.hope@alaska.gov; 907-334-2654 ***These slides had to be submitted in December 2014 and may contain outdated information***
More information340B Drug Pricing Program Results of a Survey of Eligible but Non-Participating Rural Hospitals
340B Drug Pricing Program Results of a Survey of Eligible but Non-Participating Rural Hospitals A Joint Publication of The North Carolina Rural Health Research & Policy Analysis Center (1) Working Paper
More informationJason Mills, PharmD, MBA Pharmacy Supply Chain Manager Medical University of South Carolina
Jason Mills, PharmD, MBA Pharmacy Supply Chain Manager Medical University of South Carolina Statement of Conflicts of Interest I(Jason Mills) have no actual or potential conflict of interest in relation
More informationan analysis of 340B solutions a white paper by Michael J. Sovie, Pharm.D., MBA
an analysis of 340B solutions a white paper by Michael J. Sovie, Pharm.D., MBA Disclaimer Please be advised that the following information is provided for reference purposes only. This information does
More informationTHE 340B DRUG DISCOUNT PROGRAM A Review and Analysis of the 340B Program
THE 340B DRUG DISCOUNT PROGRAM A Review and Analysis of the 340B Program WINTER 2013 A publication of the following organizations: the Biotechnology Industry Organization (BIO), the Community Oncology
More informationJuly 27, 2015. Dear Acting Administrator Slavitt:
Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-2390-P P.O. Box 8106 Baltimore, MD 21244-8016 Re: Proposed Rule for Medicaid and Children
More information340B DISCOUNT DRUG PROGRAM OVERVIEW
340B DISCOUNT DRUG PROGRAM OVERVIEW March 2014 Investment banking services are provided by Harris Williams LLC, a registered broker-dealer and member of FINRA and SIPC, and Harris Williams & Co. Ltd, which
More informationI. Policy Purpose. II. Policy Statement. III. Policy Definitions: RESPONSIBILITY:
POLICY NAME: POLICY SPONSOR: FRAUD, WASTE AND ABUSE COMPLIANCE OFFICER RESPONSIBILITY: EFFECTIVE DATE: REVIEW/ REVISED DATE: I. Policy Purpose The purpose of this policy is to outline the requirements
More informationPreventing Fraud, Waste, and Abuse
2013 Compliance Training for Contractors and Vendors Module 2 Preventing Fraud, Waste, and Abuse For Internal Training Purposes Only 1 Learning Objectives After completing this training, learners will
More information