Navigating the Journey of 340B
The 340B Drug Discount Program stems from the Office of Pharmacy Affairs’ mission to promote access to cost effective pharmacy services. 340B allows covered entities to “stretch scarce Federal resources as far as possible, reaching more eligible patients and providing more comprehensive services” as covered entities receive an average savings of 25-50% on outpatient drug purchases for 340B; those savings are then used to reduce the price of pharmaceuticals for patients.
To participate in the 340B Program, eligible organizations and covered entities must register and be enrolled with the 340B program and comply with all 340B program requirements. New registrations are accepted January 1-15, April 1-15, July 1-15, and October 1-15 each year. Covered entities must recertify their eligibility annually and notify the Office of Pharmacy Affairs whenever there is a change in eligibility.
It has been said that 340B implementation is a journey, not a destination, and those that choose to take the journey need to remain focused on continuous compliance every step of the way. Suggestions for success include dedicating the right resources, creating a 340B committee, and establishing appropriate self-audit and external-audit practices to drive continual compliance and help ensure that the answer is always ‘yes’ when asked if ready for a Health Resources and Services Administration (HRSA) audit.1
Pharmacy software with 340B capability is another recommended compliance piece with 340B. When researching software capable of assisting a 340B operation, recommended features to consider include:
*Multiple Inventories – 340B guidelines require that only 340B eligible prescriptions be filled using 340B eligible inventory. Pharmacy software should have the ability to group drugs and maintain individual and group quantity on hands for reorder and filling purposes.
*Inventory Management – If a patient, facility, or prescriber is 340B-specific, pharmacy software can save time by automatically assigning the prescription to the 340B inventory at the filling of a new prescription or refill.
*Reporting Capabilities – Software with a robust reporting system helps eliminate some stress when it’s time for an audit. Having an accessible record of required information at the click of a mouse is possible with advanced reporting functionality in pharmacy management software systems.
340B can seem like an intimidating opportunity, but many facilities are successfully participating. Multiple resources are available for assistance from registration to implementation to compliance and audit protection assistance. For more information about 340B, please visit www.hrsa.gov/opa or www.340bpvp.com (Apexus).
1Neal, Daniel. “Are We There Yet? 340B: It’s a Journey, Not a Destination.” Thought Leadership. Cardinal Health, 29 Feb. 2016. Web. 6 Apr. 2016.