fear of change€¦hrsa pharmacy services support center update lisa scholz, pharmd, mba, senior...

HRSA Pharmacy Services Support Center

UpdateLisa Scholz, PharmD, MBA, Senior DirectorHRSA Pharmacy Services Support Center

December 6, 2009 ASHP Midyear Clinical MeetingLas Vegas, Nevada

Innovation in today’s

economy

1

Change-the only constant

2

340B Resources

3

Other Government Pharmacy Programs

4Non-

government Program Funding

5

Grants

6

Medicare and Medicaid Payment

7

Other 3rd

Party Opportunities

8

Contacts

9

Objectives

Why innovate now?

Walgreens vs. Rite AideBest Buy vs. Circuit CityBrooks Brothers vs. Casual CornerMacy’s vs. FoleysSears vs Montgomery WardsYour Competitior vs YOUR Health-SystemICE HARVESTING

Why not innovate?

METOPHISOPHOBIAFEAR OF CHANGE

Change-the only constant

How do you spot the fear of change?How to present change to win?

2009 Midyear Clinical Meeting Supplemental Handout

© 2009 American Society of Health-System Pharmacists of 13

Who are 340B innovators?

Consolidated Health CentersFederally Qualified Health Center, or FQHC look-alikesFamily planning (Title X)Ryan White Care Act (Parts A, B, C, D) grantees

Black lung clinics

Comprehensive hemophilia diagnostic treatment centers

Native Hawaiian health centers

Urban Indian organizations

Certified tuberculosis clinics

Certified sexually transmitted disease clinics

Certain disproportionate share hospitals (>11.75%) and

most recently certain Children’s Hospitals

Who are your partners?

Colleges of PharmacyFederal agenciesState and Local GovernmentColleges of MedicineSchools of NursingSchools of Public HealthOther 340B entitiesLocal business

Federally qualified health centersWholesalersPharmacy Services Support CenterPrime Vendor ProgramCommunity groups supporting the underservedState Rural Offices

340B Program AdministrationThe 340B Program Team

HRSA’s Office of Pharmacy Affairs

Pharmacy Services Support Center (PSSC/PharmTA)

340B Prime VendorProgram (PVP)

340B Program

PSSC

PVP

OPA

Integrity

AccessValue

Integrity

Integrity Resource

Develops innovative pharmacy

service models and supports

technical assistance

Serves as Federal resource

for pharmacy practice

Administers 340B program

• Access to affordable drugs

• Application of “best practices”

Office of Pharmacy Affairs (OPA)

• Efficient pharmacy management

• Systems to improve patient outcome

Importance of Comprehensive Pharmacy Services

Value Resource

Offers value added products

and services

Offered at no cost to entity

Negotiates sub-ceiling prices

Helps with access to drug

distribution solutions

Value

Prime Vendor Program (PVP)



Access Resource

Helps eligible entities,

implement and optimize the

340B program

Providesinformation resources,

policy analysis &education

Access

Pharmacy Services Support Center (PSSC)

• Call Center

• Web Site

• Outreach Program

• Pharmacy Technical Assistance Program

Operates

PSSC: Interface

First established through a contract between American Pharmacists Association (APhA) and HRSA, signed September 27, 2002. Contract renewed in 2007.

The Faces

An Overview

Our Promise

High quality performance to empowerstakeholders to achieve integrity, access, and value from the 340B Program through freeservices that simplify the complex.

Our Mission

Optimize the value of the 340B Program

and provide clinically and cost effective pharmacy services

that improve medication use and advance patient care.

Technical Expertise on 340B Program Guidance and Pharmacy Operations

Trust to provide accurate information

Responsiveness to inquiries

Our Values



Question #1

What about PSSC’s Mission, Promise, and Values charges you to utilize this FREE resource?

PSSC Core Business ElementsInformation management

Organizing pharmacy expertise and resourcesResponding to 340B inquiries Pharmacy technical assistance

Policy analysisMonitoring pertinent policy developmentsCommunication and education on policy issues

NetworkingCommunication and educationPresentations and webinarsProject development

340B Entity Locations by State

654

275

66

1364

865

373557337264

592

112

14,076Total Entities

90 HI

71AK420

239

217

106282

57

43

43

108

182

244

49

584

219406796

415363

54

34182

123141

136522

83

478

304

271 MD

111 CT

189

38 DC

45 NH59 VT

198 NJ49 DE

48 RI

300 MA

10 VI

86 PR

American Samoa 1 FS of Micronesia 2 Guam 6 Marshall Islands 4 Palau 1

340B PSSC Inquiries by State

205

61

34

395

192

121

1237628139

59

Total Inquiries*

32 HI

22AK108

68

70

1635

21

16

4

28

32

60

11

227

29 5157

7169

45

6335

2739

48167

33

103

92

96 MD

29 CT

40

52 DC

9 NH13 VT

87 NJ12 DE

18 RI

70 MA

2 VI

22 PR

American Samoa 0 FS of Micronesia 0 Guam 3 Marshall Islands 0 Palau 0

*October 2007 to present

5106

CHC 19.54% DSH 16.41% FP 3.99% Consultants 3.82%Manufacturers 3.78%Wholesalers 3.13%4.75% UnknownNon-participating 20.41%

Who calls PSSC? Questions #2

When you look at the map, what does it convey to you about your rural area and PSSC’s ability to be a resource? Are you one of our callers?



Information Analysis and ManagementPSSC Call Center and Technical Assistance

1-800-628-6297 [email protected]

PSSC Website

http://pssc.aphanet.org/

PSSC Call Center Inquiries• How do I add another site/location?• How do I change my address or update the OPA

database?• Where can I find salaries for pharmacists in our

region?• How do I develop a sliding fee scale?• Can someone assist me with 340 management

resources?• What form do I complete for a contract pharmacy

arrangement?• What clinical pharmacy tools are available to help my

center?

PSSC Testimonials

“My interaction with this group involved a quick, complete, and precise response to my inquiry...”

“Your service is a life saver! Thanks again.”

“…helpful and sincerely interested in making sure all my questions were answered.”

340B PSSC Advanced Technical Assistance

6

4

0

14

2

8

7415

7

191Total Entities*

1 HI

2 AK1

3

3

22

1

2

1

1

3

3

1

9

1 03

12

20

14

58

1

2

9

2 MD

0 CT

1

0 DC

0 NH1 VT

6 NJ2 DE

2 RI

0 MA

0 VI

1 PR

American Samoa 0 FS of Micronesia 0 Guam 2 Marshall Islands 0 Palau 0 PR1

*October 2007 to present

4

Advanced Technical AssistanceClinical pharmacy services

• Formulary Management• Medication Therapy

Management

Pharmacy model selection• In house staffing• Contract pharmacy• Telepharmacy

Technology• Split billing• Automation

Compliance review• Policy and procedures• Check list

340B decision analysis• Meet with stakeholders

Entity savings from PSSC site visits this year:

$1,385,000

Question #3What motivates you about the services

available to call PSSC for assistance? If something is missing from the list of value added services, what would you add?



Information Analysis and Management

http://pssc.aphanet.org/PSSC Website

Let us help you simplify the complex…

Information Analysis and ManagementKnowledge Management System

Information Analysis and Management: Policy Blast

Question #4

What about this resource from PSSC drives you want to turn your computer on and use it??

Relationships and NetworkingLive Presentations to stake holdersArticles in journals and

Pharmacy TodayLive WebinarsLinkedin- 340B Resource NetworkFocus groups- Office of Rural Health Policy

• Dialogue and collaboration with other safety net stakeholder organizations-American Society of Health-System Pharmacists



Question #5

Are you a current user of Linkedin? What about this new social networking tool, specific to 340B entities, creates excitement to use it?

Program Development

Education and Tools for covered entities

pssc.aphanet.org/resources

Available now!

PSSC, Children’s Hospitals, PVP, OPA, and 340B 101

Program Development: Financial Analysis

Question #6How can you apply these resources to

your organization? What could PSSC do to facilitate working with the rural communities to foster a partnership to demonstrate utility of these tools to your practice settings?

Collaborative with FDA Office of Woman’s Health

Goal: Promote Patient Safety, Health Care Quality, and Health Outcomes

• Educational Series- future CE module on how to utilize FDA resources

• Brochure and literature available for FREE

Program Development: FDA Materials

Download at: http://pssc.aphanet.org/fdaform.htm



Program Development:Updated My Medicines Brochure

Program Development:Available in Other Languages

CambodianChineseHmongJapaneseKoreanLaotian

PolishSamoanTagalogThaiVietnameseArabic—Coming Soon!

Download at: http://pssc.aphanet.org/fdaform.htm

Program DevelopmentNEW Medication Booklets

First of Its KindLists all FDA approved productsBrand & Generic NamesGeneral Safety WarningsTips for Safe Medicine UseQuestions to ask thehealth care providerAvailable in ENGLISH only.

DepressionCholesterolHigh Blood PressureSmoking CessationHIV/AIDSMenopauseBirth Control

Program Development: Poison Control

Poison Control Educational Series coming soon: Module 1 “The Abuse of Prescription Pain Pills”

Question #7

What about these government partnerships to improve quality

healthcare excites you?

Program Development: FRN Notice



Question #8What tools and resources would assist

you in understanding changes in the 340B Program? What form of communication works best for you?

Non-government program funding pearls

Patient Assistance ProgramsDrug discount cards“Think outside the box”- Casinos!Project Chance Awards

Project Chance

Awards through the Pharmacy Services Support Center and Academy of Student Pharmacists at APhA

• $2000.00• Encourages pharmacy students to work

with 340B entities to develop innovative programs in the safety net community

• Deadline: January 5th

• Requirement: Poster presentation and Annual Project Report

Project Chance Statistics

Began in 2004 with 11 applicants, 5 Awards

2005-2009

•62 applicants•44 awards

Past Applicant Projects• Diabetes• Anticoagulation• 340B enrollment• Medicare Part D• Needle Exchange Program• Vaccination Program

Other Government Pharmacy Program Pearls

Vaccines for ChildrenTuberculosisSTDFamily Planning- Title X FundingTransplantRyan White/ADAPHealth Departments partnershipsLocal government (City or County)Federal government (Mississippi Delta)State Pharmacy Assistance Program (SPAP)

Medicare

Medication Therapy Management (Part D)Incident to (Part B)Facility Fees (Part B)Diabetic Supplies (Part B) DMEPOSMedicare-Diabetes Self- Management Program (DSMT)

Medicare Benefits Manualhttp://www.cms.hhs.gov/manuals/Downloads/

bp102c15.pdf



Medicaid

Outpatient/retail prescriptionsWest Virginia 340B dispensing co-pays Missouri State Medicaid Clinical Program-mental health targetNorth Carolina Poly PharmacyTexas Preferred Drug List/ Prior Authorization exemptions granted for 340B programs

Grant Opportunities

Pssc.aphanet.orgGrants.govWholesalersManufacturersFoundations

Local/State/National foundations

Other 3rd Party Opportunities

Patient Self-Management ProgramsPreventive medicine counseling and risk factor reduction intervention 99401-99404 Vaccination programsTele-pharmacyMail Order UtilizationPay for Performance IncentivesPatient Cost Sharing

Contacts:

www.hrsa.gov/opawww.hrsa.gov/patientsafety

pssc.aphanet.org

[email protected]

1-800-628-6297

www.340bpvp.com

[email protected]

1-888-340-2787

Pharmacy Services Support Center

Prime Vendor Program



Rural DSHs: FAQs and Misconceptions

- Help! I don’t know where to go for help. I’ve asked other hospitals and no one seems to have an answer. The program is too overwhelming.

PSSC PharmTA can help! When a site requests PharmTA, a 340B pharmacy expert is matched with an entity to provide assistance in any of the following areas that the entity requires:

340B Information/Education Provide assistance with alternative method conceptualization

340B Policy Interpretation Provide guidance regarding 340B inventory separation/replenishment

Enroll in 340B and Prime Vendor Programs Provide wholesaler or Prime Vendor assessment/guidance Provide guidance/business plan for implementation of pharmacy services

Facilitate entity information change in OPA database

Resolve 340B price dispute

Evaluate of specific pharmacy options for covered-entities (ex. contract, in-house, contract management company, PBM, telepharmacy, mail-order)

Advise regarding 340B program compliance Provide recommendations for maximizing 340B utilization

The technical assistance is delivered via a combination of phone, email, and site visit interactions and the mode of TA delivery will be determined by the unique needs of the site. The consultant will work with the entity contact to develop an objective based work plan to guide the PharmTA process.

Operation under a rigorous quality improvement policy helps PSSC ensure its services are consistent, accurate, responsive, accessible, and timely. To request PharmTA, please contact: 1-800-628-6297

- I’m not sure where to start, where can I find a basic overview of 340B for me and my staff?

PSSC has created fully narrated power point presentations to help those who are new to the program, visit the 340B Journey page, and check out the Education Modules folder (http://tiny.cc/modules) - start with 340B 101. If you have questions at any time, call PSSC at 800-628-6297.

- As a private, non-profit hospital, who can I get to create a contract or sign this certification of a contract between the hospital and state or local government form?

Any supervising official at the state or local government can sign the form. For example, the county commissioner can sign the certification.



http://tiny.cc/modules

- If I can’t access the 340B price list, how do I know that my hospital will benefit from this program?

The 340B price is non- transparent, but the 340B price is estimated as 20-50% of the Average Wholesale Price. PSSC created interactive spreadsheets for administrators to use in implementing a new 340B pharmacy program or revising an existing one. We encourage administrators to work with an experienced pharmacy consultant when using these spreadsheets part of their organization's financial analysis. You can find the spreadsheets here: http://pssc.aphanet.org/resources.htm, and call PSSC at 800-628-6297 to request assistance.

- Can you explain the GPO exclusion?

If you participate in the 340B Program for your covered outpatient drugs, you cannot purchase any covered outpatient drugs through a group purchasing organization or other group purchasing arrangement. This “GPO exclusion” is found in the 340B statute, at section 340B (a) (4) (L).

DSHs may participate with the 340B Prime Vendor Program. As part of the original 340B legislation, the government was also required to establish a Prime Vendor Program (PVP). The PVP is a voluntary program that serves 340B participants in three primary roles:

• Negotiating sub-340B pricing on pharmaceuticals

• Establishing distribution solutions and networks that improve access to affordable medications

• Providing other value-added products and services

The program provides the only legal means for 340B-eligible hospitals to conduct group purchasing and leverage their outpatient drug purchases to secure sub-340B discounts.

For more information, visit www.340bpvp.com.

- Which patients are eligible?

There is no means test or income limit regarding patient eligibility. For a DSH hospital, any patient of a participating 340B entity is considered a 340B eligible patient, regardless of payor status, provided that the following criteria are met:

1. the covered entity has established a relationship with the individual, such that the covered entity maintains records of the individual's health care; and

2. the individual receives health care services from a health care professional who is either employed by the covered entity or provides health care under contractual or other arrangements (e.g. referral for consultation) such that responsibility for the care provided remains with the covered entity.

For more information, please refer to the Final Notice Regarding Section 602 of the Veterans Health Care Act of 1992 Patient and Entity Eligibility - October 1996. ftp://ftp.hrsa.gov/bphc/pdf/opa/FR10241996.pdf

- How is billing Medicaid different when we are participating in 340B?

When participating in 340B, it is important to avoid the duplicate discount for Medicaid Patients. In other words, you cannot purchase a drug at the 340B price and then request a Medicaid rebate for



http://pssc.aphanet.org/resources.htm

http://www.340bpvp.com/

that drug. OPA offers 2 solutions to this issue. To learn more, visit: http://www.hrsa.gov/opa/medicaidexclusion.htm, or call PSSC 800-628-6297.

- How can I keep my 340B inventory separate from my other inventory?

Florida requires that separate physical inventories be maintained. Other states may allow for virtual inventories, but you should check with your appropriate state authority to determine your state’s specific requirements.

Additionally the PVP offers discounts on some virtual inventory software systems, for more information visit www.340bpvp.com.

- Why would I sign up for 340B? Our hospital doesn’t have an in house pharmacy.

You don’t need an in house pharmacy to participate. Each eligible entity site may choose to contract with a separate pharmacy to provide pharmacy services for patients. The entity sets up a ‘bill to, ship to’ account with a drug wholesaler, under which the entity buys and pays for the 340B drugs, but they are delivered to the pharmacy. The entity owns the 340B drugs, but the contract pharmacy houses the drugs and provides dispensing services to patients of the entity. Under the contract arrangement, the pharmacy provides normal business records to the entity showing the disposition of 340B inventory and the entity compensates the pharmacy for their services.

As a 340B entity, you may work with any pharmacy of your choosing provided there is a contract in place and the self-certification form is completed and sent to the Office of Pharmacy Affairs (OPA). OPA will not review actual contracts between 340B Covered Entities and Contract Pharmacies. Parties must have their own legal counsel review all contracts or other legal documents to ensure that all Federal, State and local requirements have been met. Additional information: http://www.hrsa.gov/opa/contracted.htm.

Contact PSSC for FREE services that simplify the complex!

Call 800-628-6297, email [email protected], visit http://pssc.aphanet.org.

HRSA PSSC, American Pharmacists Association, 2215 Constitution Ave., NW Washington, DC 20037-2985. PSSC provides information, education, and policy analysis to help eligible entities optimize the value of the 340B program and provide clinically and cost effective pharmacy services that improve medication use and advance patient care.



http://www.hrsa.gov/opa/medicaidexclusion.htm

http://www.340bpvp.com/

http://www.hrsa.gov/opa/contracted.htm

fear of change€¦hrsa pharmacy services support center update lisa scholz, pharmd, mba, senior...

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