340B Hospitals Urged to Adopt Code of Conduct

by admin | June 29, 2012 8:40 am

June 29, 2012—The association representing hospitals in the 340B drug discount program is urging its 850-plus members and all others enrolled to adopt six principles of responsible program stewardship.[1]

The code of conduct drafted by Safety Net Hospitals for Pharmaceutical Access (SNHPA)[2] covers how 340B savings should be used, what charity care should encompass, contract pharmacy arrangements, and other areas.[ms-protect-content id=”2799″] It comes as some in Congress are questioning covered entities’ use of 340B[3] and as the Office of Pharmacy Affairs (OPA) wraps up its recertification of hospitals’ eligibility[4] and continues its audits of covered entities.[5]

SNHPA says it supports increased program oversight and believes that its members and covered entities are using their 340B savings consistent with the program’s purpose to advance the health and welfare of vulnerable patient populations.  Nonetheless, the organization says it wants to make it clear to its members and other 340B stakeholders that covered entities must use the program responsibly.

The group points out that what it is recommending goes beyond what is required by federal law or by guidance from federal agencies.

In a June 13 memo announcing the principles’ release, SNHPA cited findings from a 2011 survey of its members[6]. It found that SNHPA hospitals are using their 340B savings to enhance their pharmacy departments’ or clinics’ ability to serve the uninsured or underinsured (93 percent); increase the total number of patients served by their pharmacy departments (71 percent); help the hospitals maintain an adequate supply of inventory to meet patient demand (67 percent); enable the hospitals to provide an outpatient pharmacy and keep it properly staffed (64 percent); allow on-site clinic dispensing instead of relying on commercial pharmacies (46 percent); avoid restrictive formularies and increase the choice of drugs and certain devices available to patients (41 percent); reduce patient wait times (25 percent); and extend pharmacy hours (19 percent).

“Participation in the 340B program is a privilege granted by Congress and financed by the pharmaceutical industry,” SNHPA’s memo continued. “Congress established the program to help safety-net providers stretch their scarce resources to serve more patients and provide more services to patients. Covered entities have a responsibility to be good stewards of the program and to use the program consistent with its intended purpose.”

“Without the 340B program, hospitals would have to scale back or terminate medically necessary services, limit access to needed equipment and supplies, and/or let go of staff,” SNHPA wrote. “Many safety-net hospitals credit the 340B program for their ability to stay financially solvent.”

The principles, which SNHPA says are common-sense standards, call for:

• Using 340B savings “to invest in maintaining, improving or expanding access to pharmaceuticals and/or other patient care services that benefit patients, in particular the low-income, uninsured and underinsured populations.”
• Maintaining “a meaningful charity care policy under which qualifying indigent patients receive medically necessary health care services, medications and pharmacy support services for free or at nominal cost.”
• To the extent that member hospitals have contract pharmacy arrangements, establishing them “to enhance convenient access to pharmaceuticals, particularly for vulnerable patient populations for whom travel to a 340B hospital to fill needed prescriptions may be prohibitive.”
• Not using drugs 340B-discounted drugs “in clinics whose primary purpose is to perform cosmetic procedures.”
• Not altering admission and/or discharge procedures “for the primary purpose of expanding use of the 340B program.”
• Only purchasing enough of a drug to meet patients’ immediate needs and “ensure the ability to meet public health, homeland security and other emergency medical requirements.”

SNHPA has a separate set of principles, which it recently updated, to help hospitals comply with the 340B prohibition against diversion[7].[/ms-protect-content]

 

Source URL: https://340bemployed.org/340b-hospitals-urged-to-adopt-code-of-conduct/

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