Pharmacy Access Office Hours - PowerPoint Presentation

Pharmacy Access Office Hours Pharmacy Access Office HoursApril 18, 2019Focus Topic: Clinic-Administered Drugs This session is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) as part of an award totaling $6,375,000. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov.

Webinar Logistics We strongly recommend calling in on your telephonePhone: 866-469-3239Access Code: 632 274 023 #Your Attendee ID: Listed below the access code in the box under “Select Audio Connection”. To ask/ answer a question, or share a comments, please use the Chat box on the right hand side of the screen You can download these slides on Noddlepod , & from NACHC’s NEW 340B / Rx webpage: http://www.nachc.org/focus-areas/policy-matters/340b / Or go to NACHC.org and search 340B

Operational UpdatesFocus Topic – Clinic-Administered DrugsQ&A – And Comment Box discussions throughout…

OPERATIONAL UPDATES Colleen MeimanSenior Policy AdvisorNational Association of Community Health Centerscmeiman@nachc.org

Additional Support for Rx Operations Tim Mallett from 340Basics is now under contract with NACHC to provide Training and Technical Assistance (T&TA) to health centers on pharmacy operations.Contract is funded through BPHC Cooperative Agreement, so:Thank you BPHC!Focus is operations, not advocacy.To access Tim’s expertise, you can either:email Colleen at Cmeiman@nachc.org oremail Tim directly at tmallett@340Basics.com and cc Colleen (This is probably the faster route….)

Discriminatory Contracting Health Centers – and other 340B providers -- are continuing to receive contract addendums from third-party groups offering reimbursement/ fee structures that are inconsistent with Congressional intent. Because this topic relates to advocacy, we cannot discuss it in this forum.

An on-line platform, limited to members of the health center “family”, to discuss pharmacy and 340B-related issues.Free & open to all health centers -- but as it’s not sponsored by BPHC, won’t go into details now. Do NOT discuss confidential details of reimbursement, etc.Sign up to join by emailing cmeiman@nachc.org or cdevoe@nachc.orgAre You on “Noddlepod”? It’s actually noDDlepod, not nOOdlepod – but I still thought the image might help.

Outreach from “DecisionPoint Research? DecisionPoint Research (DPR), an independent market research firm, has been hired by a major retail pharmacy chain to study FQHCs’ in-house pharmacies.  If you or your colleagues are contacted by DPR, please contact Colleen Meiman at cmeiman@nachc.org before responding.

Info on Medicaid & 340B For more info, contact Gavin Magaha at Apexus - gavin.magaha@apexus.com

Starting this month, 340B providers can verify that they are not being overcharged for 340B drugs.*Info is available in a new section of the Office of Pharmacy Affairs Info System (OPAIS.)The Ceiling Price Database is LIVE! * Remember that the 340B CEILING price is not always the same as the 340B PURCHASE price, since the PURCHASE price may contain “sub-ceiling” discounts & d istributor fees.

Are You Overpaying for Vaccines or IUDs? Neither vaccines nor IUDs are subject to mandatory discounts 340B.BUT… as a 340B provider, you are eligible for discounts on vaccines, and $50 IUDs (similar to Mirena.)For info on discounted vaccines, contact Apexus at 888.340.BPVP or apexusanswers@340Bpvp.com For info on $50 IUDs, contact mdiallo@medicines360.org or go www.medicines360.org

Miscellaneous Recordings of most Rx Office Hours sessions are now available on the NEW NACHC Pharmacy website.A couple months are missing due to Colleen’s IT learning curve….GAO now conducting a study of methods to avoid duplicate discounts.Increased focus on contract pharmacy compliance.If you are contacted by Kalderos, we advise you to respond promptly.

Looking Ahead Upcoming Office Hours TopicsMAY: Clinical Pharmacy 101 (Matt Bertsch)JUNE: TPAs? (Jim Donnelly) or Recent Trends in Audit Findings (Matt Atkins)JULY: Pharmacy Charges - Sliding Fee Scale & Other Considerations

More Learning Opportunities For people who work with 340B or their FQHC’s finances:340B Coalition Conference July 15-17 in Washington DC Three sessions focused specifically in FQHCs Two will focus on “Three Strategies to Optimize the value of your 340B program.”For people new to 340B:A “340B 101” webinar – in May (exact date TBD)340B University for FQHCs – Aug 17 in Chicago (right before NACHC CHI)

Email Tim Mallett at tmallett@340Basics.com for support with operational issues. (Please cc Cmeiman@nachc.org.)Sign up for Noddlepod by emailing cmeiman@nachc.org or Cdevoe@nachc.org.Contact Colleen if you are contacted by DecisionPoint Research.The Apexus website has info about Medicaid and 340B in each state. FQHCs can purchase discounted vaccines and $50 IUDs. There are several upcoming learning opportunities around 340B, geared both to “newbies” and “old hands.” Summary of Operational Updates

Please do the 1-minute evaluation https://www.surveymonkey.com/r/ZVXFWVS

Focus Topic: Clinic-Administered DrugsSpeaker: Rebecca (Becky) Cheek PharmD ., BCACPChief Pharmacy Officer-Grace Health340b Auditor/Consultant-Cheek Consulting, PLLC

340b-Clinic Administered Drugs Rebecca Cheek, PharmD., BCACPChief Pharmacy Officer-Grace Health340b auditor/consultant-Cheek consulting, pllc 18

Today’s Agenda Purchasing clinic administered drugsAuditing clinic administered drugs 19

Grace HealthGrace Health is an FQHC in southeastern Kentucky7 clinics, 39 school based health sites Has acquired 2 primary care offices over the last five yearsThe mission of Grace Health is to show the love and share the truth of Jesus Christ to southeastern Kentucky, through access to compassionate, high quality, primary health care for the whole person. 20

Clinic Administered Drugs What data does OPA ask for pertaining to clinic administered drugs in an audit?A listing of locations where health care services are provided to individuals for which the clinic deems itself responsible for the health care services provided for purposes of meeting 340B eligibilityProvide a “universe” of all 340B drug orders and administrations provided to patients from the parent site, offsite facilities/child sites, and pharmacies. Clinic administered drugs are a “universe”. 21

Carve-in vs Carve-outCHC’s must decide if they will carve-in or carve-out when registering a site on OPA. “Will you bill Medicaid for 340b drugs?”-question on OPA site pertains to clinic medications and not pharmacy.Carve in-340b drugs are purchased on 340b and billed to MedicaidCarve out-340b drugs are not billed to Medicaid 22

Carve-inYou have decided to carve-in and you registered your Medicaid billing NPI and Medicaid number on the OPA site and they are also on the Medicaid Exclusion File. What do you do now? Determine the drugs that you are going to use in the clinic.Which of those drugs are going to be billed to Medicaid? In other words, which drugs have a j-code? Or will you purchase all drugs on 340b? How will you track the 340b drugs?How will you audit the 340b inventory processes? 23

Drug PurchasingGrace Health has two purchasing accounts for each site. One is 340b and one is retail.I purchase all of the billable drugs (drugs with j-codes) on the 340b account. Ex: Ketorolac-J1885, Ceftriaxone-J0696 I purchase the rest on the retail account. Ex: Tylenol, ibuprofen, clonidine tabs, etc.I have found this is the simplest way to purchase and track clinic administered drugs but there are other ways.Ex: Purchase all on 340b and attach a code to the drugs with no j-code to track? 24

Drug AdministrationHow do you track the clinic administered drugs that are given in the clinic?Log Very time consumingMust document all drugs coming in and going outSometimes only option EMR reportOnly as good as the data entered into EMRBe aware of billing errors 25

340b Drug Log Date Invoice # Quantity received Drug admin.Quantity/ dosePatient/ DOBPrescriberTotal26

Electronic Medical Records reportIncludes:Date Patient/DOBDrug/NDCQuantity/dose givenJ-codePrescriber 27

Auditing clinic administered drugsPrepare the data needed to auditPurchasing records/invoices Log/EMR reportAuditing formsDo an actual physical inventory 28

Auditing clinic administered drugsBalance on-hand+purchases-administrations/outdates/returns/recalls/waste=Current balance on-hand. Compare purchases and administrations for the designated time period audited and determine reasonable percentage.29

Auditing forms Table 2Purchases and Dispensations Reconciliation TableTime period tested: begin date_____ to end date_____.(Attach data to substantiate reconciliation for each sample) 30 (1) 340B drug name and strength (2) NDC (if virtual inventory) (3) Billing unit per package (if virtual inventory) (4) Date range selected through today’s date (5) Beginning inventory (units) (6) (–) Dispensed (units) (7) (+) Purchased (units) (8) (=) Ending inventory (units) (9) Inventory Units Reconciled?   (10) Variance Resolved?   Yes No Yes No                                                

Clinic administered drugsCompliance is a continuous process and is the responsibility of the covered entity. Purchase drugs Administer drugs Audit drugs 31

IssuesMust include inventory process from ordering to compliance auditing in your policies and procedures and follow them.New clinic sites and eligibility. Acquired physician offices and eligibility.Billing errors.Medication documentation32

Additional Questions? Rebecca Cheek, PharmD., BCACPChief Pharmacy Officer Grace Health1019 Cumberland Falls Hwy.Corbin, KY 40701 606-526-9005 Rebecca.cheek@gracehealthky.org 33

Please do the 1-minute evaluation https://www.surveymonkey.com/r/XFHLNWC

General Q&AReminder: Qs submitted in advance get priority.

Applying Sliding Fee Scale to Rx Per HRSA/BPHC, SFDS requirements apply to the “service” part of the costs associated with providing a drug – namely, the dispensing costs. BPHC does not explicitly require FQHCs to apply the SFDS to the cost of the drugs themselves (called the “ingredient cost”), as they are considered supplies rather than services. It does allow the ingredient cost to be discounted. It’s important to make a distinction* between: Dispensing Cost – must follow SDFS rulesIngredient Cost – SDFS requirements do not apply*This distinction must officially exist for SFS drugs, even if no such distinction exists for drugs for which reimbursement is available.See Manual excerpt (on NACHC webpage) for more info on setting charges for drugs

Other Questions?

Please do the 1-minute evaluation https://www.surveymonkey.com/r/ZVXFWVS