FEAR OF CHANGE€¦HRSA Pharmacy Services Support Center Update Lisa Scholz, PharmD, MBA, Senior Director HRSA Pharmacy Services Support Center December 6, 2009 ASHP Midyear Clinical
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HRSA Pharmacy Services Support Center
UpdateLisa Scholz, PharmD, MBA, Senior DirectorHRSA Pharmacy Services Support Center
December 6, 2009 ASHP Midyear Clinical MeetingLas Vegas, Nevada
Innovation in today’s
economy
1
Change-the only constant
2
340B Resources
3
Other Government Pharmacy Programs
4Non-
government Program Funding
5
Grants
6
Medicare and Medicaid Payment
7
Other 3rd
Party Opportunities
8
Contacts
9
Objectives
Why innovate now?
Walgreens vs. Rite AideBest Buy vs. Circuit CityBrooks Brothers vs. Casual CornerMacy’s vs. FoleysSears vs Montgomery WardsYour Competitior vs YOUR Health-SystemICE HARVESTING
Why not innovate?
METOPHISOPHOBIAFEAR OF CHANGE
Change-the only constant
How do you spot the fear of change?How to present change to win?
Consolidated Health CentersFederally Qualified Health Center, or FQHC look-alikesFamily planning (Title X)Ryan White Care Act (Parts A, B, C, D) grantees
Certain disproportionate share hospitals (>11.75%) and
most recently certain Children’s Hospitals
Who are your partners?
Colleges of PharmacyFederal agenciesState and Local GovernmentColleges of MedicineSchools of NursingSchools of Public HealthOther 340B entitiesLocal business
Federally qualified health centersWholesalersPharmacy Services Support CenterPrime Vendor ProgramCommunity groups supporting the underservedState Rural Offices
First established through a contract between American Pharmacists Association (APhA) and HRSA, signed September 27, 2002. Contract renewed in 2007.
The Faces
An Overview
Our Promise
High quality performance to empowerstakeholders to achieve integrity, access, and value from the 340B Program through freeservices that simplify the complex.
Our Mission
Optimize the value of the 340B Program
and provide clinically and cost effective pharmacy services
that improve medication use and advance patient care.
Technical Expertise on 340B Program Guidance and Pharmacy Operations
Are you a current user of Linkedin? What about this new social networking tool, specific to 340B entities, creates excitement to use it?
Program Development
Education and Tools for covered entities
pssc.aphanet.org/resources
Available now!
PSSC, Children’s Hospitals, PVP, OPA, and 340B 101
Program Development: Financial Analysis
Question #6How can you apply these resources to
your organization? What could PSSC do to facilitate working with the rural communities to foster a partnership to demonstrate utility of these tools to your practice settings?
Collaborative with FDA Office of Woman’s Health
Goal: Promote Patient Safety, Health Care Quality, and Health Outcomes
• Educational Series- future CE module on how to utilize FDA resources
First of Its KindLists all FDA approved productsBrand & Generic NamesGeneral Safety WarningsTips for Safe Medicine UseQuestions to ask thehealth care providerAvailable in ENGLISH only.
DepressionCholesterolHigh Blood PressureSmoking CessationHIV/AIDSMenopauseBirth Control
Program Development: Poison Control
Poison Control Educational Series coming soon: Module 1 “The Abuse of Prescription Pain Pills”
Question #7
What about these government partnerships to improve quality
Awards through the Pharmacy Services Support Center and Academy of Student Pharmacists at APhA
• $2000.00• Encourages pharmacy students to work
with 340B entities to develop innovative programs in the safety net community
• Deadline: January 5th
• Requirement: Poster presentation and Annual Project Report
Project Chance Statistics
Began in 2004 with 11 applicants, 5 Awards
2005-2009
•62 applicants•44 awards
Past Applicant Projects• Diabetes• Anticoagulation• 340B enrollment• Medicare Part D• Needle Exchange Program• Vaccination Program
Other Government Pharmacy Program Pearls
Vaccines for ChildrenTuberculosisSTDFamily Planning- Title X FundingTransplantRyan White/ADAPHealth Departments partnershipsLocal government (City or County)Federal government (Mississippi Delta)State Pharmacy Assistance Program (SPAP)
Medicare
Medication Therapy Management (Part D)Incident to (Part B)Facility Fees (Part B)Diabetic Supplies (Part B) DMEPOSMedicare-Diabetes Self- Management Program (DSMT)
Patient Self-Management ProgramsPreventive medicine counseling and risk factor reduction intervention 99401-99404 Vaccination programsTele-pharmacyMail Order UtilizationPay for Performance IncentivesPatient Cost Sharing
- Help! I don’t know where to go for help. I’ve asked other hospitals and no one seems to have an answer. The program is too overwhelming.
PSSC PharmTA can help! When a site requests PharmTA, a 340B pharmacy expert is matched with an entity to provide assistance in any of the following areas that the entity requires:
340B Information/Education Provide assistance with alternative method conceptualization
340B Policy Interpretation Provide guidance regarding 340B inventory separation/replenishment
Enroll in 340B and Prime Vendor Programs Provide wholesaler or Prime Vendor assessment/guidance Provide guidance/business plan for implementation of pharmacy services
Facilitate entity information change in OPA database
Resolve 340B price dispute
Evaluate of specific pharmacy options for covered-entities (ex. contract, in-house, contract management company, PBM, telepharmacy, mail-order)
Advise regarding 340B program compliance Provide recommendations for maximizing 340B utilization
The technical assistance is delivered via a combination of phone, email, and site visit interactions and the mode of TA delivery will be determined by the unique needs of the site. The consultant will work with the entity contact to develop an objective based work plan to guide the PharmTA process.
Operation under a rigorous quality improvement policy helps PSSC ensure its services are consistent, accurate, responsive, accessible, and timely. To request PharmTA, please contact: 1-800-628-6297
- I’m not sure where to start, where can I find a basic overview of 340B for me and my staff?
PSSC has created fully narrated power point presentations to help those who are new to the program, visit the 340B Journey page, and check out the Education Modules folder (http://tiny.cc/modules) - start with 340B 101. If you have questions at any time, call PSSC at 800-628-6297.
- As a private, non-profit hospital, who can I get to create a contract or sign this certification of a contract between the hospital and state or local government form?
Any supervising official at the state or local government can sign the form. For example, the county commissioner can sign the certification.
- If I can’t access the 340B price list, how do I know that my hospital will benefit from this program?
The 340B price is non- transparent, but the 340B price is estimated as 20-50% of the Average Wholesale Price. PSSC created interactive spreadsheets for administrators to use in implementing a new 340B pharmacy program or revising an existing one. We encourage administrators to work with an experienced pharmacy consultant when using these spreadsheets part of their organization's financial analysis. You can find the spreadsheets here: http://pssc.aphanet.org/resources.htm, and call PSSC at 800-628-6297 to request assistance.
- Can you explain the GPO exclusion?
If you participate in the 340B Program for your covered outpatient drugs, you cannot purchase any covered outpatient drugs through a group purchasing organization or other group purchasing arrangement. This “GPO exclusion” is found in the 340B statute, at section 340B (a) (4) (L).
DSHs may participate with the 340B Prime Vendor Program. As part of the original 340B legislation, the government was also required to establish a Prime Vendor Program (PVP). The PVP is a voluntary program that serves 340B participants in three primary roles:
• Negotiating sub-340B pricing on pharmaceuticals
• Establishing distribution solutions and networks that improve access to affordable medications
• Providing other value-added products and services
The program provides the only legal means for 340B-eligible hospitals to conduct group purchasing and leverage their outpatient drug purchases to secure sub-340B discounts.
For more information, visit www.340bpvp.com.
- Which patients are eligible?
There is no means test or income limit regarding patient eligibility. For a DSH hospital, any patient of a participating 340B entity is considered a 340B eligible patient, regardless of payor status, provided that the following criteria are met:
1. the covered entity has established a relationship with the individual, such that the covered entity maintains records of the individual's health care; and
2. the individual receives health care services from a health care professional who is either employed by the covered entity or provides health care under contractual or other arrangements (e.g. referral for consultation) such that responsibility for the care provided remains with the covered entity.
For more information, please refer to the Final Notice Regarding Section 602 of the Veterans Health Care Act of 1992 Patient and Entity Eligibility - October 1996. ftp://ftp.hrsa.gov/bphc/pdf/opa/FR10241996.pdf
- How is billing Medicaid different when we are participating in 340B?
When participating in 340B, it is important to avoid the duplicate discount for Medicaid Patients. In other words, you cannot purchase a drug at the 340B price and then request a Medicaid rebate for
that drug. OPA offers 2 solutions to this issue. To learn more, visit: http://www.hrsa.gov/opa/medicaidexclusion.htm, or call PSSC 800-628-6297.
- How can I keep my 340B inventory separate from my other inventory?
Florida requires that separate physical inventories be maintained. Other states may allow for virtual inventories, but you should check with your appropriate state authority to determine your state’s specific requirements.
Additionally the PVP offers discounts on some virtual inventory software systems, for more information visit www.340bpvp.com.
- Why would I sign up for 340B? Our hospital doesn’t have an in house pharmacy.
You don’t need an in house pharmacy to participate. Each eligible entity site may choose to contract with a separate pharmacy to provide pharmacy services for patients. The entity sets up a ‘bill to, ship to’ account with a drug wholesaler, under which the entity buys and pays for the 340B drugs, but they are delivered to the pharmacy. The entity owns the 340B drugs, but the contract pharmacy houses the drugs and provides dispensing services to patients of the entity. Under the contract arrangement, the pharmacy provides normal business records to the entity showing the disposition of 340B inventory and the entity compensates the pharmacy for their services.
As a 340B entity, you may work with any pharmacy of your choosing provided there is a contract in place and the self-certification form is completed and sent to the Office of Pharmacy Affairs (OPA). OPA will not review actual contracts between 340B Covered Entities and Contract Pharmacies. Parties must have their own legal counsel review all contracts or other legal documents to ensure that all Federal, State and local requirements have been met. Additional information: http://www.hrsa.gov/opa/contracted.htm.
Contact PSSC for FREE services that simplify the complex!
HRSA PSSC, American Pharmacists Association, 2215 Constitution Ave., NW Washington, DC 20037-2985. PSSC provides information, education, and policy analysis to help eligible entities optimize the value of the 340B program and provide clinically and cost effective pharmacy services that improve medication use and advance patient care.