As anyone that has been involved in the 340B Drug Pricing Program for
any real amount of time knows, change really is one of the only constants
in this program.
Between changes in provider panels, to changes in Medicaid payer
information and integrating data, there is always something coming up. Over time, more and
more people wonder, will there even be a 340B in the future?
In the years I've been involved in 340B, I've heard this question many times. My answer is
always the same, YES. Even with recent announcements of manufacturers not allowing NDCs
to contract pharmacies, even with the processing platforms like ESP, Kalderos and others
changing how claims will process and inventory flows, 340B is not going away.
So how do you deal with these changes and still operate your 340B Program?
1) Know what is changing.
This seems like a very simple 'duh' response, but with all the different moving parts of the 340B Program, different Covered Entity and Contract Pharmacy set-ups, and even different Third Party Administration software, not all changes are going to impact every single 340B Program the same way. Some 340B programs might not be impacted at all, it all depends on what the actual change is.
2) Identify how the change will impact your program.
This is more than just surface deep. Some changes will impact the claims qualification, or disqualification, some will impact the way all parties are reimbursed. Sometimes it's a procedural change that doesn't actually impact the end result of the program. The biggest challenge is figuring out how the required change will impact your bottom line.
3) Quantify and mitigate the change's impact.
Seems pretty much a standard process in business, to be able to show how changes will impact your facility and to find solutions or ways to mitigate that impact. With 340B having so many moving parts, it can feel impossible to do. While it does take time and a thorough understanding of your 340B program, it can be done.
The simplest way to predict the change is to review all the claims that have processed for the last
3-6 months, then identify how your claims capture will change based on what is being adjusted.
If you're having to carve out additional payers because there's a new Medicaid BIN/PCN/Group, that's a fairly simple item to identify. If you're going to be losing qualification of a group of NDCS (such as in the Eli Lilly. Novartis, Sanofi, etc. notices) then you want to identify any of the involved NDCs and see what losing all of those claims, by location, will do to your bottom line.
These all take time, and it is easier to identify something being removed from the program but
what about if the change will be adding something into 340B? This is a bit of a backwards
process and involves again, knowing your 340B Program set-up, what types of places your
patients are getting 340B dispensations from, what your TPA does and doesn't have available for
reporting, and more. Then going through and simulating the change and how that would pan out
to claims qualification.
340B is such a fluid and detailed industry that having the time to do these more than full-time
projections on top of your normal duties seems almost impossible, I mean if you want sleep and
family time after all. But there are people and facilities who specialize in doing exactly these
types of things. Let them be your guide and your help. There are solutions and you can be able to
project (way better than a shot in the dark) what type of impact a change will have in your 340B
Program.
As always, you can reach out to us directly, connect with Clear340B for contract pharmacies, or
Optimal340B for Covered Entities. We are here to be your guide or your department throughout
your 340B journey.