Inventory Management. Statement of Conflicts of Interest. Today s Goals 1/29/2014

Transcription

1 10 th Annual 340B Coalition Winter Conference Inventory Management Nicole N. Crase Director of Pharmacy Five Rivers Health Centers Pharmacy February 7, 2014 Statement of Conflicts of Interest Nicole Crase has no actual or potential conflict of interest in relation to this presentation Today s Goals Describe practices of inventory management at a CHC in house pharmacy Identify strategies for maintaining entity 340B compliance with contract pharmacy 1

2 CE Question True or False The contract pharmacy, not the covered entity, is responsible for maintaining 340B compliance. Five Rivers Health Centers Serves over 15,000 patients at 48,000 visits annually Has primary and specialty care clinics Became an FQHCLA on 4/10/12 Became an FQHC on 11/1/13 Consists of 3 former residency clinics Family Health Center Medical Surgical Health Center Center for Women s Health Five Rivers Health Centers Pharmacy Contract pharmacy started July 1, 2013 In house pharmacy opened September 3,

3 CHC In House Pharmacy Physical vs. virtual inventory considerations: 340B only inventory Carve in/out Medicaid Separate retail inventory Patient assistance programs CHC In House Pharmacy We use a physical inventory only virtual inventory not needed 340B only drug inventory Carve in Medicaid All patients must fit the definition of a patient in order to utilize our pharmacy (prevents drug diversion) Ensure OPA database/medicaid exclusion file is correct (prevents duplicate discounts) CHC In House Pharmacy Identifying in house patient assistance (PA) programsphysical inventory Separate PA inventory on the pharmacy shelves from other medications Identify/mark bottles as patient assistance 3

4 CHC In House Pharmacy Identifying PA in the software system Identify this separate inventory in your software system Ie. Adding an asterisk in front of the drug name to identify difference between pt assistance medication and 340B purchased medications Identify pt assistance programs by price plans/price coding PA Sharing the Care PA AZ and Me PA Merck Patient assistance arriving by mail was coded as PA Contract Pharmacy Set Up The original expectation was that the contract pharmacy would provide resources for opening the in house pharmacy. However, it took almost a year to establish a secure way to identify eligible prescriptions. Your EMR may tell you that including a second address line site identifier isn t possible, put them in contact with sites that have already accomplished this! This was necessary to ensure 340B compliance!! Contract Pharmacy Set Up Established a unique site identifier through our EMR Our providers have their own private practices. Strictly going by an updated NPI list only was not an option! This process took almost a year to set up Accept electronic prescriptions with the site identifier and written prescriptions w/barcode sticker attached No phone in prescriptions accepted 4

5 Contract Pharmacy Set Up Currently have an open formulary The entity is ultimately responsible for 340B compliance don t take an autopilot approach! Ensure OPA registration/database is correct Prevent duplicate discounts We exclude Medicaid and Medicaid managed care patients from our contract pharmacy Self audit practices Patient eligibility EHR prescription verification Prescription inventory utilization audit Currently auditing all prescriptions filled through the contract pharmacy Verify medication, patient, eligible provider May not be feasible to audit every claim as it gets busier? Future choose 5 patients to audit daily? 5

6 Select patients filling for the first time, new rx s vs. refills, multiple first fills written by different prescribers. Verify each patient in EMR to ensure visit was completed by an eligible provider. Even if you choose to only audit 5, you are still responsible for the other prescriptions being filled. Request hard copy prescriptions we have done this Verify patient and provider eligibility Verify that dispensing was accumulated appropriately Choose to do monthly and/or as needed Prescriber audit Evaluate each prescriber used to dispense eligible prescriptions for inclusion on an eligible provider list Eligibility may be based on NPI. We use a site identifier. Send updated provider eligibility list Possibility of the incorrect prescriber name being typed on prescription even with electronic prescriptions. Is the incorrect provider name an eligible provider? 6

7 Contract Pharmacy Client Reporting System Utilize the client reporting website to verify: Contract pharmacy records against the EHR Estimated cost vs. actual amount paid Dispense to accumulation reports Purchasing inventory reports Financial statements including aged to accumulation, etc. Contract Pharmacy Documentation Log all self audits Keep documentation of dialogue with the contract pharmacy Keep documentation of invoices, inventory and financial reports, etc. Contract Pharmacy Future Decisions Future issues to be determined: Consider excluding 500ct and 1000ct NDC s anything greater than 100ct bottles from the formulary? Consider excluding drugs from the formulary as we get our aged to accumulator reports? 7

8 CE Question True or False The contract pharmacy, not the covered entity, is responsible for maintaining 340B compliance. CE Question & Answer True or False: The contract pharmacy, not the covered entity, is responsible for maintaining 340B compliance. Answer: False Additional Questions? Nicole N. Crase Director of Pharmacy Five Rivers Health Centers Pharmacy 725 S. Ludlow Street Dayton, Ohio Phone: