June 14, 2012—The Health Resources and Services Administration (HRSA) is seeking a contractor to review the Office of Pharmacy Affairs’ (OPA) 340B covered entity audit reports and “provide feedback on any identified issues,” according to a June 11 notice posted on the Federal Business Opportunities Web site.
In addition, the “pre-solicitation” notice states that the contractor will identify trends that emerge from the audits and “make suggestions for policy improvements, training opportunities, development of tools and resources, etc.”[ms-protect-content id=”2799”] OPA has conducted 37 of the 50 audits planned for this year but has not yet released any findings.
The contractor’s scope of work will also encompass 340B policy analysis, professional development, and communications tasks now handled in varying degrees by OPA’s two current major contract agencies, the Pharmacy Services Support Center (PSSC) and the 340B Prime Vendor Program (PVP).
The contract to operate PSSC, which has been held by the American Pharmacists Association (APhA) since 2002, expires later this year. HRSA signaled in March that it intended to re-compete the contract when it posted a notice on the same federal procurement Web site inviting small and minority-owned businesses to describe their capacity to operate PSSC. At the time, APhA said it would pursue the contract again. The June 11 notice does not mention PSSC and it is not known if it is related to the PSSC contract.
In response to a request for comment, a HRSA spokesperson said the agency had no additional information to provide at this time.
HRSA said in the June 11 notice that it would issue a formal request for proposals (RFP) in about 15 days, which would be on or about June 26. Proposals will be due 30 days after the RFP is published, which would be in late July. The notice does not say when HRSA anticipates making its final selection.
The notice indicates that the contractor will be an influential actor in 340B affairs generally and, notably, in OPA’s immediate and long-term follow-up to the audits of 340B covered entities now underway.
According to the contract description, the awardee will be “a national source of support and expertise” for HRSA, its grantees, and for 340B safety-net providers. Its work will fall under two broad categories: (1) program integrity, information, and analysis; and (2) program development.
Its duties will include:
- Reviewing 340B covered entity audit reports, A-133 audits, and program site-visit reports “in order to provide feedback on any identified issues.”
- Analyzing the same reports for trends and providing OPA with “suggestions for policy improvements, training opportunities, development of tools and resources, etc.”
- Accompanying auditors up to 10 times per year “as subject matter experts.”
- Educating stakeholders about 340B program integrity requirements.
- “Conducting policy and pharmaco-economic analysis related to current and changing state and federal laws and regulations affecting the scope and delivery of pharmacy services, in general, and in the specific jurisdiction of HRSA grantees, or others eligible to participate in the 340B program.”
- Measuring the impact of comprehensive pharmacy services initiatives on 340B entities and their patients and advising OPA on the subject.
- Providing “training on best practices in effective management of pharmacy services,” including “the development and operations of formularies and the establishment of therapeutic committees including their compositions, how decisions are made, effective communication approaches, and evidence-based decision needs.”
- Developing expertise “within the consultant cohort to provide pharmacy technical assistance about 340B.”
- Developing expertise “within participating 340B entities to provide technical assistance through the 340B Peer to Peer Program.”
In terms of overall duration, the one-year base contract with four option years would mirror those for PSSC and PVP. In 2009, HRSA signed Apexus to a two-year base contract to run PVP with three option years, the first of which HRSA exercised last October. Apexus is a nonprofit subsidiary of the group purchasing organization Provista. It began managing PVP under its earlier name, Healthcare Purchasing Partners International, in 2003.[/ms-protect-content]