Critical Access Hospital (CAH) with 3 sites in rural Ohio was not registered in the 340B program. One site contained an open-door infusion center in the basement, administering medications to patients written by the hospital’s providers, as well as those from unaffiliated providers. They inquired with RPHI to provide 340B Program Support services to build and optimize their program from scratch.
The covered entity had no internal resources with 340B experience and inefficient, manual processes of tracking in-clinic administrations for the infusion center to quantify the 340B savings that could be generated as a result. Additionally, the hospital opened 2 new provider-based outpatient facilities not yet listed on the Medicare Cost Report.
Utilizing 30+ years of 340B program management expertise, RPHI executed a plan to quantify the opportunity and maximize savings via operational changes at the infusion center, split-bill implementation, contract pharmacy expansion and drafting custom policies and procedures.
Optimizing 340B at the infusion center
With only rudimentary knowledge of 340B eligibility and ‘the patient definition’, the hospital was under the impression they could only qualify infusion prescriptions for established patients that were written by the hospital’s dedicated providers. RPHI’s 340B Officer educated the appointed Authorizing Official and Primary Contact of their ability to qualify every prescription, even those written by unaffiliated providers. The 340B Officer instructed hospital staff to record specific information in the EHR for every patient receiving an infusion, then drafted custom policies and procedures for the covered entity, outlining the hospital’s definition of eligible patient. The hospital would now capture 40% more prescriptions coming into the infusion center.
Expanding the contract pharmacy universe
RPHI leveraged our working relationships with all of the major pharmacy chains and associated TPAs to expedite contract pharmacy opportunity analysis and implementations for our client. 11 contract pharmacies (3 independents, 1 specialty, 7 chain stores) were registered across 3 different TPAs over the next registration cycle. RPHI’s familiarity with each TPA, and individualized educational sessions for the independent pharmacies, resulted in smooth implementations before the effective go-live dates.
RPHI played an instrumental role in split-bill vendor selection based on the client’s current and future needs. The 340B Officer supported the hospital’s appointed 340B purchaser during implementation, and drafted policies and procedures to alleviate complexities of in-clinic administration (via the Limiting Drug definition and waste policies).
Capitalizing on RPHI’s 340B expertise, relationships and production, the client realized 340B savings that would otherwise have gone unnoticed or extended into many subsequent quarterly registration cycles. RPHI’s 340B Program Support took the hospital from $0 to $100,000 per month in the same amount of time the hospital had projected to fill the role of 340B coordinator. RPHI continues to achieve year over year 340B revenue growth for the client, prospecting and implementing new strategies and technologies.
A 3-site FQHC in Idaho, participating in 340B with 2 contract pharmacies was seeing their 340B revenue decrease to ~$18,000 per month. The FQHC contracted with RPHI to uncover and fix the 340B leakage.
Looking over the data, RPHI discovered that the client was engaged in a self-pay contract with a carry forward model (pay upon replenishment) in which self-pay claims were trued up at retail cost rather than replenished at 340B, costing them thousands in drug costs. In addition to the mishandled self-pay claims, the client’s TPA failed to negotiate proper switch fees, further decreasing the client’s 340B profit.
Fixing Self-Pay Leakage
RPHI advised the client to turn off their current self-pay program until the TPA could implement an auto order mechanism. This allowed the client to fill accumulated orders and reduce the cost of their previous self-pay program, ultimately leading to the significant monthly savings increases.
Fixing TPA Fees
RPHI reviewed the client’s contracts with all current 340B vendors and discovered an abnormally high switch fee acquisition cost in the TPAs contract. Having market knowledge across all of the major TPAs, RPHI recognized this and negotiated a decrease in the TPAs switch fees by 70%.
Having access to 340B experts from RPHI led to not only to recovery, but increased savings with existing parameters and vendors. And the optimization didn’t stop there. RPHI continues to expand and manage contract pharmacy partnerships, increasing the client’s monthly 340B savings by 580%.
A small disproportionate share hospital (DSH) in rural Louisiana mostly surrounded by independent pharmacies.
The client had recently heard about the benefits of the 340B program, but had no prior experience and a limited budget to hire expert consultants to determine if they were even eligible. Furthermore, neither the hospital or their surrounding independent pharmacies had internal resources that could ensure proper registration, implementation, and ongoing management of a 340B program if they were to start.
After some pro-bono consulting and analysis, the client entrusted RPHI to oversee registration, train staff, and provide daily compliance and operational support via 340B Program Support services.
RPHI got to work right away reading through the Medicare Cost Report and trial balance to determine site eligibility and roadmap an implementation plan for policy & procedure drafting, split-billing and contract pharmacy expansion. All eligible sites were registered with OPA along with Wal-marts and 2 of the 4 local independent pharmacies, all within 4 weeks of contracting with RPHI. This was no small feat as RPHI was both leading registration, education facilitation of contracts for both the entity and independent pharmacies before the quarterly OPA registration deadline.
After the hospital was approved for 340B, RPHI’s assigned 340B Officer immediately got started on drafting policies and procedures, leading implementations for the newly registered pharmacies, and prospecting for the best split-billing vendors to meet the hospital’s need. Over the course of the next 3 months, RPHI outlined responsibilities and compliance procedures to be conducted by the entity to maintain compliance, while continuing to manage and expand the contract pharmacy universe. By the next registration cycle, RPHI negotiated terms with the 2 most profitable pharmacies for the hospital, both independents that needed a lot of education and reassurance about entering into a 340B agreement.
In only 2 registration cycles, RPHI 340B Program Support services took a non-existing 340B program to one that generates over $960,000 in annual savings. RPHI continues to serve as the 340B department for the covered entity, leading 340B steering committee meetings and optimization efforts with emerging technologies, like automated referral capture across multiple TPAs.