(Updated on July 17 with comment from the American Pharmacists Association)
July 16, 2012—The Health Resources and Services Administration (HRSA) has formally opened the competition for a contractor to support its 340B program integrity efforts and perhaps take over enrolling and recertifying providers in the drug discount program. Bids are due by 2:00 p.m. (Eastern) on August 9.
The content and timing of the July 9 request for proposals (RFP) also raises questions about the future of the Pharmacy Services Support Center (PSSC), at least in its present form and under its current name.[ms-protect-content id=”2799″]
The contract to operate PSSC, held by the American Pharmacists Association (APhA) since 2002, expires this fall. The new RFP does not mention PSSC. Apart from posting an equal opportunity “sources sought” notice in late February for the PSSC contract, HRSA has taken no steps to re-bid it. Given the short amount of time remaining on the contract, it appears more and more that the new competition is for PSSC’s successor.
APhA said earlier this year that it would pursue the PSSC contract again and late in the day on July 16 said that its position has not changed. So far, nine companies have added their names to a public list of vendors interested in the new contract. Two of them—Ramsell and Maxor National Pharmacy Services—have extensive experience with the 340B program. More companies and nonprofit groups are expected to bid on the contract as well.
The new RFP fleshes out the new contract agency’s duties, many of which are now carried out by PSSC. The main ones include:
- Reviewing and analyzing 340B covered entity and HRSA grantee audit reports and suggesting policy improvements and training opportunities
- Accompanying auditors on covered entity audits up to 10 times per year
- Analyzing state and federal laws and regulations affecting 340B specifically and pharmacy services more broadly
- Studying and providing information and training about comprehensive pharmacy services
- Educating HRSA staff and grantees about grant requirements
- Educating 340B stakeholders about the drug discount program and its program integrity requirements
- Providing best-practices training about pharmacy management
- Assembling a team of 340B consultants
- Managing the 340B Peer-to-Peer network
- Assessing and making recommendations on state pharmacy strategies regarding formularies, pharmacy benefits, and disease management programs.
The item about 340B audits says the contractor should be prepared to review up to 100 covered entity audits reports and up to 100 HRSA grantee audit reports per year. That would be double the number of covered entity audits as were performed this year. HRSA had not previously indicated how many so-called A-133 audits of grantees it planned to do annually.
The contract is for one base year with up to four optional years. Specific tasks for the first year include:
- Publishing up to 50 articles on the delivery of pharmacy services, including policy papers “on maximizing the benefits of 340B discounts for safety-net providers”
- Developing and implementing a training plan about 340B for HRSA staff and program stakeholders that addresses program requirements and benefits for participating providers
- Developing a plan to manage pharmacy consultants and the 340B Peer-to-Peer program.
One noteworthy task for the contract’s optional years is to “provide for registration/change requests/re-verification/recertification for all categories of covered entities.” All of this work related to OPA’s 340B covered entity database is currently handled by the agency’s own staff.
Another notable option-year task is the creation of a “level II and III communications center” to answer “in-depth and complex issues that require more consultant expertise in areas such as pharmacy operations, auditing, and financial analysis.”
“Level I assistance will continue to be performed by the OPA staff, HRSA Information Center (1-800-ASK-HRSA) and the 340B Prime Vendor,” the RFP continued. The task description does not mention PSSC or its telephone call center.[/ms-protect-content]