August 28, 2012—Without 340B drug discounts, safety-net hospitals and community health centers (CHCs) would find it difficult, if not impossible, to continue providing free or reduced-cost comprehensive pharmacy care to the poor and uninsured, top senior executives at six 340B hospitals and centers said during a recent Pharmacy Services Support Center (PSSC) webinar.
But because 340B “has so many moving parts,” as one executive put it, providers should devote significant attention to ensuring that their programs comply with federal guidelines and rules.[ms-protect-content id=”2799″] One of the best ways to go about this, the executives agreed, is to make sure that the institution’s lead pharmacist is integrated into the hospital’s or CHC’s management structure.
PSSC’s 340B Peer-to-Peer Network held the Aug. 22 webinar to give hospital and CHC leaders an overview of 340B from the perspective of the “C-suite,” a business term for the echelon of management whose members have the word “chief” in their titles. These executives’ critical role in 340B was highlighted earlier this year during the first annual recertification of hospitals’ eligibility for the drug discount program. As the individuals legally responsible for authorizing their hospitals to participate in 340B, they had to personally certify that all of their institution’s information in the Office of Pharmacy Affairs (OPA) covered entity database was accurate. They also had to attest that their institution met all 340B eligibility requirements.
OPA recently announced that recertification of 340B health centers will begin in January, with the first notification emails being sent to centers’ authorizing officials in November.
During the webinar, George Masi, chief operating officer of the Harris County Hospital District (HCHD) in Texas, said that the 340B program “is absolutely critical” to the public health system’s performance. More than 60 percent of the system’s patients are unable to pay for their care, he noted. “Without the 340B program, we would have a very difficult time meeting our mission.”
The other executives on the panel made similar observations. Jay Breines, executive director of Holyoke Health Center in Massachusetts, said revenue from its 340B pharmacy enables it to provide prescriptions with fact sheets and in unit-dose packaging that enhance patient safety and improve medication adherence. Participating in 340B, he said, helps Holyoke “make it as easy as possible for our patients to take very complicated medication regimens, improving health outcomes.”
Revenue from the pharmacy also “is helping us to fund other programs,” he continued. “Without the pharmacy, we’d be scrounging, quite frankly.”
Janis Sunderhaus, chief executive officer of Health Partners of Western Ohio, said revenue from its 340B pharmacy “goes to help support our dental program, where we have high uninsured rates.”
Earnings from participation in 340B “go right back into our programming,” she continued. Before enrolling in 340B, the center’s three sites relied heavily on sample medications “and our providers were constantly stressed out about where they were going to get medications for their patients.” Now, Sunderhaus said, “our in-house pharmacy assures that all our patients have access to 340B pricing.”
Brian Toomey, chief executive officer of the health center network Piedmont Health in North Carolina, called the 340B program “a win-win” that increases access to medication for the poor and uninsured and at the same time increases revenue that the network uses in other areas. Through its participation in 340B, Piedmont has been able to offer uninsured patients $4.00 pricing on their prescriptions. “If you’re committed to making sure that patients get high-quality care at the best pricing, there’s nothing better to make that happen than 340B,” Toomey said.
Sunderhaus noted that many providers eligible to enroll in 340B “are frightened off” from doing so because the program “operates in a constantly changing environment” and “needs more attention and management” that many other government programs.
Two keys to running a successful 340B program, she said, are keeping abreast of new guidance and rules from Washington and “keeping communication open between your pharmacy director and senior management.”
“In our organization, our pharmacy director is part of our leadership team and involved in all overall organization strategy,” she said.
Others on the panel agreed that giving pharmacists a role in decision-making was critical both operationally and in terms of 340B regulatory compliance.
During that past year, the Harris County health system moved its chief pharmacy officer, Ryan Roux, “directly in line with the chief operating officer,” said Masi, the COO.
“That allows me to get the updates and briefings and insights I need,” he said. “A successful 340B program requires collaboration among the leadership and the line staff. The devil is in the details and to have that expertise right at hand is critical.”
Roux, the system’s head pharmacist, said Harris County has developed 340B policies and procedures addressing procurement, patient eligibility, and general pharmacy operations. It also maintains separate inpatient and ambulatory care pharmacy purchasing accounts to prevent mixing of stock, conducts its own random audits of 340B transactions, and uses the health system’s staff development center “to assure that our pharmacy staff stays up to date on the newest 340B regulations.”[/ms-protect-content]