340B. Simplified. Defining 340B. Created in 1992 to: Expand access to affordable medications for low-income patients Enable hospitals to stretch their resources to provide more comprehensive care for the uninsured population Eligibility: Entities (must be non-profit) - PowerPoint PPT Presentation
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Confidential, proprietary and possible Trade Secret of SUNRx and MedImpact (See Slide #1)
The contents of this presentation are confidential and proprietary to SUNRx and MedImpact Healthcare Systems, Inc. and may contain material MedImpact considers Trade Secrets. This presentation may not be reproduced, transmitted, published, or disclosed to others without prior written authorization from SUNRx and MedImpact Healthcare Systems, Inc.
Confidential, proprietary and possible Trade Secret of SUNRx and MedImpact (See Slide #1)
Defining 340B
Created in 1992 to:o Expand access to affordable medications for low-income patientso Enable hospitals to stretch their resources to provide more comprehensive care for the
uninsured population
Eligibility:o Entities (must be non-profit)
• Federally Qualified Health Centers, Disproportionate Share Hospitals, Critical Access Hospitals, Children’s Hospitals and others
o Medications• Outpatient drugs only
o Patients• Only patients of covered entities
Oversight Responsibility:o Health Resources and Services Administration (HRSA)
Confidential, proprietary and possible Trade Secret of SUNRx and MedImpact (See Slide #1)
Patient Definition
HRSA Patient Eligibilityo The covered entity has established a relationship with the individual,
such that:1. The entity maintains records of the individual's health care2. The prescriber is either employed by the covered entity – OR3. The prescriber provides health care under contractual or other
arrangements (e.g., referral for consultation)4. The responsibility for the care remains with the covered entity
Confidential, proprietary and possible Trade Secret of SUNRx and MedImpact (See Slide #1)
Data Elements Obtained to Determine Eligibility
Eligible Service Areas
o SUNRx will identify the hospital’s outpatient (OP) service areas that are on the Medicare Cost Report—used to code the VI system.
Eligible Events
o SUNRx will establish a real-time feed of the hospital’s ADT system to document patient visits to the hospital.
Eligible Timeframe
o SUNRx will assign the script an appropriate capture time frame based on the establishment of an Eligible Event (i.e., one year) and the provider type.
Eligible Providers
o SUNRx will obtain a list of hospital providers who are classified as employed, contracted or credentialed, and determine their exclusivity to the hospital. This determination will be used to define SUNRx’s prescription capture rules.
Eligible Pharmacy
o SUNRx will obtain data on all prescriptions filled for hospital patients at the contract pharmacy (either retrospectively or in real time.)
Confidential, proprietary and possible Trade Secret of SUNRx and MedImpact (See Slide #1)
340B Guidance
HRSA Auditso HRSA conducts audits to assure entities are:
• Preventing diversion of 340B Drugs (use only for eligible patients)• Preventing duplicate discounts (Medicaid rebate + 340B discount)• Maintaining readily auditable records• Adhering to the GPO and Orphan Drug Exclusions
Internal Auditso HRSA expects entities to perform annual “independent” 340B auditso Self Audits—random audits of contract pharmacy claimso Self-Reporting of program violations to HRSA
Annual Facility Recertification—Entities should:o Assure that contact information is up to date on the HRSA websiteo Make sure OP facilities are registered with HRSAo Facilities are on their Medicare Cost Reporto Contracts are in place and annual audits are conducted
Confidential, proprietary and possible Trade Secret of SUNRx and MedImpact (See Slide #1)
Maintenance of Auditable Data
• Eligible patients• Eligible events at the hospital• Eligible providers (by type)• Captured claims from eligible pharmacies• Reviewed and accepted ICD-9 matched claims• Wholesaler orders placed for drug, at each contract pharmacy• Pharmacy receipt of replenished drug• Documentation of all “blocked” Medicaid claims• Results of financial reconciliation