Management of an in-house 340B pharmacy by a hospital is often times more complex and complicated than the hospital’s administrators may had initially anticipated. On the “surface” a hospital or healthcare system administrator can easily see the potential profitability that the specialty pharmacy can generate for them. Ever since the creation of the federal 340B Drug Discount Program in 1992, the program has been seen as the primary catalyst for the rapid growth and expansion of specialty pharmacies in hospitals and healthcare system facilities that’s been occurring over the past decade or two.
The 340B Program was actually a section of the Public Health Service Act (PHSA) that was signed into law by then President George Bush and was intended by the HRSA (U.S. Department of Health and Human Services, Health Resources and Services Administration) to allow covered entities to “stretch scarce federal resources as far as possible, reaching more eligible patients and providing more comprehensive services.” The new program was aimed at both maintaining the levels of services provided to patients, while at the same time lowering the patient’s medication costs.
340B Hospital Pharmacy Medication Management Review – Case Study
Recently Healthcare Consultants was hired for our nationally renowned Pharmacy Consulting Services by a hospital located in the Northeastern US that’s a part of a large community healthcare system with multiple locations. Initially engaged by the hospital’s administration to perform reviews of the facility’s medication security and accountability (with a focus on CS), we were additionally tasked with identifying any other areas of risk exposure that currently existed (or could potentially arise sometime in the foreseeable future).
The Medication Management Review that HCC performed identified several existing areas of risk that were present at the hospital:
– Significant gaps were identified in the controlled substance monitoring program in place.
– Ineffective Medicaid billing practices were in place.
– Poor data management within the 340B system was seen, leading to a large potential for inaccurate billing.
– A high potential for diversion existed (ineligible prescription dispensing).
– The potential of medication use that is outside of the scope of the 340B program existed.
– An increased risk of potential regulatory actions and recoupment demands (potentially in the millions of dollars).
– Pharmacy management concerns were identified and documented.
– Poor communication (both vertically and horizontally) with the hospital’s senior leadership team was identified (as relating to increased pharmacy risks being present).
– A lack of transparency within the pharmacy department was documented, enabling the operation’s staff to practice “siloing” and isolate from one another.
– Inadequate forecasting and planning processes were in place.
– No accountability system in place that would allow the hospital’s administrators the ability to measure their pharmacy’s performance.
The outcome of our findings and report resulted in several key middle and senior management changes, a complete recasting of their 340B program management, a thorough review of their billing procedures, plus a complete pharmacy department “overhaul” under a brand new leadership team. Healthcare Consultants additionally has provided the hospital with both ongoing support and guidance in several key areas afterwards.
Summary of this 340B Case Study
For entities that are currently considering adding a 340B program (or expanding their existing 340B program), proper attention must be given to the structure, scope, and data management that’s required. Inattention at any point of your planning process in any of these areas can easily lead to improper program utilization, which can potentially result in some extremely large recoupment demands being made following an audit. Paybacks in the range of several hundreds of thousands to even several millions of dollars are not unusual. HCC has health system pharmacy experts and 340B program experts that can help you to identify your hospital’s areas of risk exposure and provide remedial solutions to better protect a healthcare system from adverse regulatory and payer outcomes.
About HealthCare Consultants
From major hospitals and healthcare systems to individual community pharmacies, HCC has been the nationally renowned pharmacy consulting firm of choice for over 30+ years now. We work with businesses of every size – from the corner drug store to national corporations and organizations – with our primary goals being: improve your business’s operations and help increase your company’s profitability. We can help assist you with expert advice in any area of your pharmacy business or practice.
We urge you to contact us today to see how our Pharmacy Consulting services can help you improve your business now, plus be ready for the future. With a full-time staff of in-house Pharmacy Consultant specialists, HCC can answer any questions that you may have in all pharmacy settings. Contact us online or call us today at 800-642-1652 for a free consultation.