340B FTE Request Template Slide Deck Purpose and Instructions - PowerPoint Presentation

340B FTE Request Template Slide Deck

Purpose and Instructions Instructions Aspects of the presentation should be tailored to your organization’s mission and valuesSlides will note where organization-specific information is necessaryBest practice: obtain your annual 340B purchases and calculate 340B savings to fully optimize this presentationFor assistance with calculating 340B savings, check whether your wholesaler provides a report comparing 340B purchases to what the price would have been on a WAC or GPO account Reference the Dashboard Best Practices Tool, available at https://www.340bpvp.com/education/340b-tools/ This template contains core slides that are appropriate for all entity types and a separate appendix to select specific slides that pertain to your FTE requestThe notes section below includes slide background and instructions PurposeThis tool serves as a customizable template to support new 340B-related staff requests by the hiring manager (manager/director/VP) to present to the organization’s C-suite (approving body)

340B Program Overview Intent To permit covered entities to stretch scarce Federal resources as far as possible, reaching more eligible patients and providing more comprehensive services. H.R. Rep. No. 102-384(II), at 12 (1992)The 340B Program gives health care providers who are responsible for larger proportions of vulnerable patients the ability to purchase medications at a reduced price ““

340B Program Overview Example Physician administers 340B drug to an eligible outpatient 340B price: $70Non-340B price: $100340B savings: $30Best practice: 340B savings reinvested in entity servicesExamples: community benefit, charity care, drug access programs, free clinics, sliding fee scales Non-340B acquisition cost: $100 –340B acquisition cost: $70$30 savings from 340B Savings Entities generate savings by purchasing 340B drugs at a lower price than what they would have paid if not participating in 340B (i.e., GPO or wholesaler pricing)

*Entity Name* 340B Savings Physician-administered/clinic savings $___ savings Entity-owned retail pharmacy savings$___ savingsContract pharmacy impact$___ savings340B compliance maintenance costs$ –___ costs340B net financial i mpact$___ savings

Importance of 340B Resources Program Compliance and Optimization Lead 340B self-auditsReadiness for HRSA and manufacturer auditsProvide relationship and oversight of third parties340B vendorsContract pharmaciesOptimize program value to the entityLead 340B oversight councilRespond to manufacturer inquiriesProvide ongoing staff educationCommunicate 340B savings and how they are used

Importance of 340B Resources Consequences of HRSA audit and noncompliance Repayment to manufacturers Termination of covered entity from 340B ProgramTermination of child sites from 340B ProgramTermination of contract pharmacies from 340B ProgramIncreased scrutiny from state Medicaid programs

*Insert slide from “Appendix I – Benchmarking” based on our CE type* Include your annual outpatient drug expenses 340B Resources Benchmarking

340B FTE Request with JD *Insert slide from “Appendix II – Job Descriptions” with entity-specific data pertaining to your request* Include primary focus of the position you are requesting Show how the cost of the FTE is offset by affecting 340B savings and minimizing compliance risk

Oversight Council *Insert slide from “Appendix III – Oversight Council” with entity-specific data pertaining to your request*Include this slide only if you’re planning on having this FTE lead or be part of your oversight council

Conclusion Recap FTE request and purpose of role Summarize benefit of position and risks without the role

340B Resource Trends According to a 2019 American Society of Health-System Pharmacists (ASHP) survey of multi-hospital pharmacy executives: “340B System Manager” was the third most common system-level pharmacy position “340B System Manager” was the second most common position reporting to the system-level Chief Pharmacy OfficerRespondents reported the position “340B System Manager” to have the following number of direct reports: 0-3: 34 respondents (64%)4-9: 13 respondents (25%)10-15: 6 respondents (11%)

GPO Prohibition Hospital Benchmarks (DSH/PED/CAN) Outpatient drug expenses Average number of 340B FTEs% with an oversight council% completing monthly audits% said had enough resources% said confident could pass an audit<$10M (n=6)1.1250%50%17% 33%$10M–$35M (n=4)5.17100%75% 67% 100% $35M–$75M (n=5) 4.47 100% 80% 80%100%>$75M (n=3)6.6767%67%33% 67%

Outpatient drug expenses Average number of 340B FTEs % with an oversight council % completing monthly audits% said had enough resources% said confident could pass an audit<$100K (n=2)0.3550%50%0%0%$100K–$325K (n=4) 0.5850%75%25% 25% $1M–$1.5M (n=2) 2.35 50% 0% 50%100%>$30M* (n=3)8.25100%100%100%100% Rural Hospital Benchmarks (CAH, SCH, RRC)

Community Health Center Benchmarks Outpatient drug expenses Average number of 340B FTEs % with an oversight council% completing monthly audits% said had enough resources% said confident could pass an audit<$101K (n=3)0.650%33%100% 100%$101K–$499K (n=5) 0.6040%40% 80% 60% $500K–$1M (n=4) 0.89 25% 25% 75%75%>$1M (n=7)1.7225%57%38%88%

Outpatient drug expenses Average number of 340B FTEs % with an oversight council % completing monthly audits% said had enough resources% said confident could pass an audit<$101K (n=7)0.650%33%100%100%$101K–$499K (n=7) 0.6040%40%80% 60% $500K–$1M (n=2) 0.89 25% 25% 75%75%>$1M (n=3)1.7225%57%38%88%Grantee Benchmarks

340B Registration Responsible for 340B OPAIS accuracy as primary contact Policy and Procedure Development Monitors newly passed legislation and guides program changesCollaborates with 340B Prime Vendor Program on best practicesAudit Supervisor Develops and executes regular auditing program Evaluates necessary self-reporting and needed program changesProgram Optimization Reviews and negotiates new 340B contracts Assesses opportunities for cost savings (sub-WAC, sub-340B)*Pull relevant duties from 340B Manager and Coordinator JD Template Tool on 340bpvp.com/education/340b-tools*340B Manager/Coordinator Job Duties

Auditing Participate in self- and external audits of 340B Program Evaluate patient eligibility and 340B compliance Financial Analysis Recognize 340B financial impactReporting Develop reports to assist in tracking financial impact of 340B to the entityMonitor, report, and analyze contract pharmacy data Split-Billing Supervise and audit 340B split-billing software; coordinate purchasing and buyer compliance *Pull relevant duties from 340B Analyst JD Template Tool on 340bpvp.com/education/340b-tools*340B Analyst Job Duties

340B Program Manager 340B Coordinator 340B Analyst Average Salary$93,389$64,612$54,216Salary Range$40,000–$175,000$30,000–$150,000$25,000–$80,000Pharmacist Average$140,000 (n=5)$140,000 (n=2)N/ANon-Pharmacist Average$76,743 (n=14)$54,560 (n=15) $54,216 (n=10) Salary Benchmarking

Key Roles of 340B Oversight Council Responsible for operational and strategic decision making to ensure integrity of the program Ensures that 340B savings are used in accordance with program intent Reviews self-audit results, ensure that discrepancies are corrected, and determine material breach of compliance process requiring self-disclosure to HRSAImproves understanding of the 340B Program across the organization340B Oversight Council

Per the 2017 Prime Vendor Program member survey, organizations with 340B oversight councils were:27% more likely to perform audits on a monthly basis, allowing them to more quickly make operational changes to support complianceMore likely to be confident in their ability to pass an audit Oversight Council Benefits