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Pharmacy Access Office Hours

Learn about strategies and value of tracking clinic-administered drugs in a webinar supported by HRSA. Operational updates and legislative information included. Helpful tips for engaging with unfamiliar groups. Noddlepod assistance and tips provided.

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Pharmacy Access Office Hours

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  1. Pharmacy Access Office Hours Pharmacy Access Office Hours September 19, 2019 Focus Topic: Clinic-Administered Drugs: Value & Strategies for Tracking This session is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) as part of an award totaling $6,375,000. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov.

  2. Webinar Logistics We strongly recommend calling in on your telephone Phone: 866-469-3239 Access Code: 632 274 023 # Your Attendee ID: Listed below the access code in the box under “Select Audio Connection”. To ask/ answer a question, or share a comments, please use the Chat box on the right hand side of the screen You can download these slides and two attachments on Noddlepod, & from NACHC’s 340B/ Rx webpage: http://www.nachc.org/focus-areas/policy-matters/340b/ Or go to NACHC.org and search 340B

  3. Operational Updates • Focus Topic – Clinic-Administered Drugs: Value and Strategies for Tracking Them. • Q&A – Becoming a contract pharmacy • And Comment Box discussions throughout…

  4. OPERATIONAL UPDATES Colleen Meiman Senior Policy Advisor National Association of Community Health Centers cmeiman@nachc.org

  5. Summary of Operational Updates • If unfamiliar groups reach out with questions or opportunities around 340B – be cautious! • Five states have passed laws restricting discriminatory contracting under 340B. • NACHC is developing/ identifying: • Educational materials around USP 800 (effective date: 12/1/2019) • A template for P&Ps for pharmacy operations • The next HRSA registration window is October 1-15; please use this if possible, and be prepared to submit your contracts with new pharmacies. • We need your help to: • Share documents on Noddlepod – e.g., competency tests for staff, one-pagers on 340B • Review the draft plan for one-day regional trainings on 340B compliance and operations.

  6. Caution Needed • If unfamiliar groups reach contact you with questions or opportunities around 340B – be cautious! • Several groups are actively seeking info or action from health centers for reasons that are not aligned with our patients’ best interest and/or the intent of the program. • The number of such group has skyrocketed in recent months.

  7. If an unfamiliar group contacts you… • Ask who is funding them and what their goals are. • Ask your health center colleagues if they know the group • Noddlepod is a good way to do this. • Be particularly suspicious if they are offering to increase your patients or 340B revenue • If in doubt, please do not respond. • One exception: Kalderos – a private group seeking data re: duplicate discounts on behalf of drug manufacturers. See new info on Noddlepod.

  8. State Legislation to Address Discriminatory Contracting • West Virginia • 3/1/19 Gov signed into law SB489 • A PBM cannot reimburse 340B entities at a rate lower than non-340B entities • South Dakota • 3/07/19 Gov signed into law HB1137 • No PBM can discriminate against a pharmacy participating in a health plan as an entity authorized to participate in 340B program. • Montana • 4/30/19 Gov signed into law SB335 • A PBM cannot pay less than the state-surveyed average drug acquisition cost or WAC for 340B dispenses

  9. State Legislation to Address Discriminatory Contracting, cont. • Minnesota • 5/20/19 Gov “approved” into law SF278 • A PBM may not reimburse an entity or pharmacy under contract with such entity differently that other similarly situated pharmacies • Does not apply to PBMs under contract with state for Medicaid MCO • Oregon • 7/15/19 Gov signed into law HB2185 (effective 1/1/2020) • A PBM registered under ORS 735.532 may not reimburse a 340B pharmacy differently than any other network pharmacy based on its status as a 340B pharmacy.

  10. Noddlepod – Your Help Needed! We need more posts -- with documents attached -- for the following: • Sample CAD tracking/audit forms • One pagers – 340B benefit for your CHC • Patient education – on pharmacy, 340B, SFS etc. • Competency testing for pharmacy staff • Quizzes to be used during performance reviews • Math, 340B and general pharmacy knowledge

  11. Noddlepod Tips • Attaching documents • You cannot attach a document when replying to someone else’s post.  • To get around this: • Create a “new” post, and attach the doc to that. • Reply to the original post, and tell people where to find the attachment • If that doesn’t work, email them to Tim at tmallett@340basics.com • Categories: • Don’t worry if you can’t find a category that matches your post. • Tim Mallett reviews all uncategorized posts and either finds a category or creates a new one.

  12. USP 800 • The US Pharmacopeia (USP) has issued new rules around the handling of “hazardous” drugs in healthcare settings. • They go into effect on December 1, 2019. • Shorthand name is “USP 800.” • Tim Mallett is looking for resources re: how to implement the new rules in a small retail pharmacy setting (e.g., a health center in-house pharmacy.) • If you know any good resources, please share with Colleen (cmeiman@nachc.org) or Tim (tmallett@340basics.com) • Stay tuned for more info next month, and on the NACHC webpage.

  13. In the Works – Template P&Ps for Pharmacy Operations • NACHC is developing a template set of Policies and Procedures for Health Centers’ Pharmacy Operations. • Will pull from many sources, including: • Apexus P&P template • HRSA expectations re: P&Ps • P&Ps shared by individual health centers. • Please contact Colleen (cmeiman@nachc.org) or Tim (tmallett@340basics.com) if: • You are willing to share your health centers’ P&Ps. • You have specific suggestions or questions regarding the template.

  14. 340B Registration Window Coming Soon • Next window will run Oct. 1- Oct. 15. • New sites and contract pharmacy arrangements will become eligible on Jan. 1, 2020. • FQHCs that register new contract pharmacy arrangements may be asked to send the contract to HRSA, who will verify that was signed and dated appropriately, etc. • Registrations outside this window should be requested only when absolutely necessary.

  15. Future Learning Opportunities • October 17 Office Hours – Tips for Reviewing Insurance Contracts for Pharmacy Services • November 21 Office Hours – A Model for Implementing SFS at a Contract Pharmacy • Starting early 2020 - One-day regional trainings on 340B compliance and operations.

  16. Your Help Needed – Again! • The one-day regional trainings are being planned by Tim Mallett and Matt Atkins. • To ensure that the sessions are as valuable to health centers as possible, we would like your input on the agenda, topics, times, etc. • A draft plan is in the attachments. Please send input to tmallett@340Basics.com and MAtkins@draffin-tucker.com

  17. Are You Overpaying for Vaccines or IUDs? • Neither vaccines nor IUDs are subject to mandatory discounts 340B. • BUT… as a 340B provider, you are eligible for discounts on vaccines, and $50 IUDs (similar to Mirena.) • For info on discounted vaccines, contact Apexus at 888.340.BPVP or apexusanswers@340Bpvp.com • For info on $50 IUDs, contact mdiallo@medicines360.org or go www.medicines360.org

  18. Summary of Operational Updates • If unfamiliar groups reach out with questions or opportunities around 340B – be cautious! • Five states have passed laws restricting discriminatory contracting under 340B. • NACHC is developing/ identifying: • Educational materials around USP 800 (effective date: 12/1/2019) • A template for P&Ps for pharmacy operations • The next HRSA registration window is October 1-15; please use this if possible, and be prepared to submit your contracts with new pharmacies. • We need your help to: • Share documents on Noddlepod – e.g., competency tests for staff, one-pagers on 340B • Review the draft plan for one-day regional trainings on 340B compliance and operations.

  19. Please do the 1-minute evaluation https://www.surveymonkey.com/r/YT7T6NV (Your responses help us demonstrate to BPHC that these sessions are a valuable use of their funding.)

  20. Focus Topic Strategies and Value of Tracking Clinic-Administered Drugs* Sabrina Allen, PharmD, Sr. Director of Pharmacy Services, Family Medicine Residency of Idaho* The handouts include a written case study of this health’s center’s experience.

  21. Questions for Sabrina? And please do the one-minute evaluation: https://www.surveymonkey.com/r/YT7T6NV

  22. General Q&AReminder: Qs submitted in advance get priority.

  23. Becoming a Contract Pharmacy Q: Can a health center with an in-house pharmacy serve as a contract pharmacy for another health center? A: Yes. Q: If so, what issues should the in-house pharmacy consider when becoming a contract pharmacy? Response: Felicity Homsted, Former Chief Pharmacy Officer for a Health Center; presently with Turnkey

  24. Other Questions?

  25. Please do the 1-minute evaluation https://www.surveymonkey.com/r/YT7T6NV

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