End of Month Reporting in a 340B Contracted Pharmacy Arrangement

1. End of Month Reporting in a 340B Contracted Pharmacy Arrangement Jerry Sveum Sveum Consulting Feb1, 2008

2. Necessary Reports 1. Inventory Report 2. Transaction Logs A. Cash transactions B. Formulary Vouchered Transactions 3. Third Party Reports 4. Non-Formulary Vouchered

3. Formulary Drugs Computer set up in Drug Record Tag formulary drugs in Drug Record Screen (P drugs) Add asterisk or other identifying mark to the formulary drug name or code for ease and accuracy of the drug selection process. Add 340B cost field Set On Hand to zero to start if using a replenishment system.

4. Sample PDX Drug Record Screen

5. Sample QS/1 Drug Record Screen

6. The Replenishment Model Use pharmacy owned inventory to fill the prescription Track the amount used and replenish by purchasing stock on a 340B account set up for the clinic with a drug wholesaler, a ship to / bill to arrangement.

7. Inventory Report  Must be run on last day of the month or billing period Run report for only the Formulary Drugs Include: Name, Strength and NDC of the Drug Amount on hand Unit 340B cost of the Drug Line extension total value on hand Column total of the line extension

8. Insert Inventory Data on EOM Form

9. Transaction Logs Prescriptions sold for cash or paid with a voucher, B or EV transactions Drug Cost + Disp fee + Admin fee = Rx Price for cash (B) transactions Drug Cost + Disp fee = Rx Price for Vouchered transactions

10. Insert Transaction Data on EOM Form

11. Third Party Reports Transmit third party claims using the pricing terms of the pharmacy. Example AWP -15% + $2.50 BUT use 340B priced drugs from the clinic. The difference in the spread between the 340B cost and the AWP-15 cost belongs to the clinic because they are clinic owned drugs.

12. Insert Third Party Rx Data

13. Non-Formulary Vouchered Transactions Rxs filled using pharmacy owned (non-formulary) drugs. Use pharmacies U&C pricing but with a separate price code to isolate these vouchered Rxs the clinic is to pay.

14. Insert Non-Formulary Data on EOM Form

15. Not Picked Up- Return to Stock For the same month / reporting period just reverse the transaction. No special reporting For later months, reverse the transaction but report it to recover the payment made to the clinic the previous month.

16. Insert Non-Picked Up Rx Data on EOM Form

17. The Payment At end of reporting period pharmacy writes a check to clinic for the reported sales found at cell E8 of the form. Clinic writes a check back to the pharmacy for the earned dispensing fees reported at cell F8

18. Payment From Form

19. Conclusion Data generated is adequate for clinic to spot check pharmacy for diversion of drugs and accuracy of reporting the financial aspects of the program� program accountability. The data described is adequate to protect the clinic and pharmacy should they be subject to a federal audit.

20. Free Form To receive an End of Month Report form already set-up for you in Excel format contact Jerry Sveum to have it emailed to you. Contact info: Jerry Sveum sveums@charter.net (608) 362-5906