340B Insight

340B hospitals must navigate the challenging world of pharmacy supply chain management, in which they must balance budget constraints while providing high-quality care to all their patients. In this episode, we explore best practices for how hospitals can manage the 340B pharmacy supply chain. Our guest is Ashley Covert, system director of pharmacy supply chain and contracting at Dartmouth Health. 

Before the interview, we give an update on two problematic bills approved by the House Energy and Commerce Committee that would have adverse effects on 340B hospitals if they were to become law.

Pharmacy Supply Chain's Growing Prominence
The pandemic spotlighted supply chain management and its influence on health care delivery and patient care. Ashley emphasizes how hospital pharmacy leaders can ensure the efficient management of their supply chains and the timely provision of patient care by staying informed and actively engaged with industry developments.

Hospital Access to Medications
Supply chain challenges often are exacerbated by factors such as global manufacturing problems and staffing shortages. Ashley gives strategies that leaders can adopt to overcome these obstacles and ensure patients have access to medication.

Leveraging Data and Analytics
Ashley explains how pharmacy leaders can optimize their budgets and prepare for potential disruptions more effectively by adopting a data-driven approach to managing the pharmacy supply chain. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you’d like us to cover in this podcast, email us at [email protected].

Resources

Joint Statement from National Hospital and Pharmacist Associations on Harmful House 340B Legislation
House Committee Approves Problematic 340B Reporting Legislation

340B Coalition Summer Conference Registration

Several of the drug companies restricting 340B discounts on drugs dispensed at contract pharmacies have created policies that say they will restore the 340B prices if covered entities submit patient claims data. In this episode, we dive deeper into these claims submission conditions with Jesse Breidenbach, vice president of pharmacy at Sanford Health and a member of the 340B Health Board of Directors. Jesse shares best practices for navigating the challenges when drug manufacturers demand claims data.

Before the interview, we give an update on a drug company placing additional restrictions on its 340B pricing and recap a recent 340B advocacy event on Capitol Hill.

The Impact of Drug Company Restrictions

The restriction of 340B discounts has had a substantial financial impact on Sanford Health. Jesse shares how these restrictions have made it more difficult for Sanford to obtain 340B savings and use them to provide care to its patients.

Making the Decision to Submit Claims Data

Responding to companies whose policies require submitting patient claims data requires critical decision-making by hospitals. Jesse explains what is involved in submitting the data, how to decide if submitting is a viable option, and what steps hospital 340B teams need to take to prepare their data submissions.

What Happens After Claims Are Submitted?

Jesse explains how quickly discounts might be restored after submitting the claims, how consistently drug companies are keeping the 340B pricing in place, and the challenges hospitals face when dealing with discrepancies between claims. 

Resources

1. 340B Health Contract Pharmacy Infographic
2. Bayer Is Latest Company to Tighten 340B Restrictions
3. 340B Health Hill Day Features Advocacy for Introducing Contract Pharmacy Bill
4. 340B Coalition Summer Conference 2023 Registration

A recent report from 340B Health includes data on how drug company restrictions on 340B hospital partnerships with community and specialty contract pharmacies have taken a toll on the health care safety net and the patients who rely on it. On this episode, we speak with the report’s author, 340B Health Vice President of Research and Policy Analytics Caroline Steinberg, to walk through the findings and discuss what they mean for 340B hospitals and their patients. Before the interview, we provide a news update on a federal appeals court case regarding a 340B non-discrimination law in Arkansas.  

The Data Behind the Report

Caroline discusses the primary data sources for the report, including data from the federal government and survey results from 340B Health members. 

Tip of the Iceberg 

The report breaks down the amount of savings stripped from the health care safety net in 2021 from the five companies restricting 340B discounts for all of that year. Caroline uses this information to project the billions of dollars in annual lost 340B savings from the contract pharmacy restrictions. She also describes the patterns she found in the types of drugs that drugmakers are restricting. 

The Toll on Patient Care

340B hospital survey data in the report uncovers how lost 340B savings from drug company restrictions affects patients’ access to services and their ability to obtain discounts on medications through contract pharmacies. Caroline discusses results from the survey that shed light on how drug company demands for patient claims data are diverting resources from patient care. She also shares individual stories from the report of harm to patient care. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources 

1. 340B Health, AHA, Arkansas Hospital Association Urge Federal Appeals Court to Uphold State Law Protecting 340B Community Pharmacies
2. 340B Health Spring 2023 Report on Contract Pharmacy Restrictions 
3. 340B Health Spring 2023 Contract Pharmacy Report Infographic
    
4. 340B Coalition Summer Conference 2023 Registration  

340B contributes vital resources toward the pursuit of health equity for historically underserved communities. As we recognize National Minority Health Month, we speak with Fatimah Muhammad, director of 340B pharmaceutical services and drug replacement at Saint Peter’s University Hospital in New Brunswick, N.J. Fatimah discusses how her hospital uses 340B to address maternal health disparities, including support for a birth center to improve maternal health outcomes. Before the interview, we provide news updates on new 340B legislation in Congress and changes to drug company contract pharmacy policies.

Causes of Maternal Health Disparities 

Fatimah shares data demonstrating disparities in maternal health outcomes and discusses the role that social determinants of health play in health disparities. 

The Saint Peter's Approach to Maternal Health
Saint Peter's University Hospital created a birth center that has adopted a midwifery model of care. Fatimah discusses how the birth center incorporates doulas into patient care and how it approaches high-risk pregnancies. She also notes that the birth center cares for all patients no matter their health insurance status.

340B’s Role in Maternal Health
Saint Peter's has used its 340B savings to provide maternal health services and expand its family health center. The hospital’s plans for continuing to support maternal health include creating a food pantry for mothers and families who are experiencing food insecurity.  

Check out all our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources 

1. 340B Health Statement on the Protect 340B Act to Ban Discriminatory Payment Policies 
2. Novartis Is Latest in String Of Companies Tightening 340B Restrictions 
3. 340B Health Contract Pharmacy Dispute Resources for Members 
4. National Minority Health Month 

340B helps health systems and hospitals stretch their resources and provide more services to patients in need. This makes 340B important to a hospital or health system leadership team’s ability to plan how it will deliver care. In this episode, we speak with Matthew Perry, president and CEO of Genesis Healthcare System in Zanesville, Ohio. Matt shares his perspective about 340B and how 340B professionals can best engage with their hospital CEO. Prior to the interview, we share findings from a new 340B Health report about the effects of drug company 340B contract pharmacy restrictions on patient care. 

Economic Challenges

Many hospital CEOs face economic challenges in their organization. Matt shares the value that 340B leaders provide to help hospitals have the resources they need to meet their patient care mission. 

How to Engage Hospital CEOs in 340B Operations and Advocacy 

Matt provides best practices for how 340B professionals can best educate the CEO about 340B to help the CEO strategize how to use 340B savings to grow and sustain services for patients in need. He also discusses why 340B hospital CEOs should become engaged in program advocacy. 

Connecting 340B Professionals to the C-suite 

Matt describes how he and his leadership team support 340B program leadership and established an organizational structure for communication with the health system’s 340B program leader. He also shares advice for 340B professionals who are interested in a health system C-suite career path. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources 

1. 340B Health March 2023 Report on Drug Company 340B Contract Pharmacy Restrictions 
2. Joint Statement from National Hospital and Pharmacist Associations on PhRMA-led Proposal to Restrict 340B Eligibility
3. Matt Perry Op-ed about 340B Providing Stability for Hospitals Amid the COVID-19 Pandemic 

340B compliance is a critical requirement for hospitals participating in the program, and one of the ways 340B hospitals maintain compliance is through conducting internal audits. For this episode, we speak with Tristan Greer, 340B program business manager at Catholic Health in Buffalo, N.Y. Tristan has significant experience conducting 340B internal audits at the health system, and she shares several best practices for a successful internal audit. Before the interview, we provide a news update on how drug manufacturers are pursuing legislative changes to 340B and some of the responses to that proposal. 

The Benefits of Internal Audits 

Internal audits help 340B covered entities stay in compliance. Tristan outlines the internal audit process her health system uses and how this supports the overall compliance effort. She also explains how the internal audit process has changed over time. 

What HRSA Expects from Internal Audits

Tristan discusses what HRSA expects hospitals to share about their 340B internal audits. 

Staying Organized During Internal Audits 

Tristan shares her approach to accomplishing a successful internal audit, including which materials her hospital gathers for the process. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you’d like us to cover in this podcast, email us at [email protected].

Resources 

1. 340B Health Statement on PhRMA Proposal to Reduce Safety-Net Hospital Participation in 340B
2. Rep. Doris Matsui Statement on Proposal to Change 340B Program 
3. PhRMA Unveils More Details About Proposed 340B Hospital Eligibility Cuts 
4. 340B Coalition Winter Conference  

State policymakers have increased the attention they are paying to 340B. In this episode, we hear from 340B state advocacy expert Abby Reale. Abby is director of government and external affairs with Mountain Health Network in West Virginia. The state has been a leader in protecting 340B, and she shares how her health system worked with other hospitals and provider organizations to advocate for the first 340B non-discrimination law in the nation. Prior to the interview, we provide a news update about a drug company that is imposing the pharmaceutical industry’s most restrictive limits on 340B pricing.  

Why You Need to Pay Attention to State Health Policy  

Abby discusses the power states have to regulate health care. 

Advocating for a 340B Non-Discrimination Law 

Abby details the steps her hospital and other provider organizations took to help state legislators understand the need to stop payer and pharmacy benefit manager (PBM) payment discrimination against 340B providers. She also explains the work advocates sometimes need to do to ensure laws are enforced. 

Joining 340B State Advocacy Efforts 

Abby shares how 340B professionals can join advocacy efforts in their states and how advocacy differs between the state and federal levels. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources 

1. Statement on New Johnson & Johnson Restrictions on 340B Access 
2. Contract Pharmacy Dispute Resources for 340B Health Members
3. 340B Coalition Winter Conference 

Health information technology (IT) is intertwined with 340B operations and compliance. So how can hospitals and health systems manage IT while keeping 340B in mind? To find out, we hear from Robert Owens, director of pharmacy enterprise shared services at Atrium Health. Bob is a pharmacy health IT expert, and he shares how the technology intersects with 340B. He also shares insights to ensure strong 340B operations and compliance when undergoing an electronic health records (EHR) system conversion. Before the interview, we provide an update on two more drug companies restricting 340B discounts.  

IT's Intersection With 340B Operations

Bob discusses the different types of IT systems providing data that are important for closely monitoring your 340B program, including electronic health records, automated dispensing cabinets, and IV workflow software. He emphasizes the importance of the 340B team members becoming experts on 340B data. 

EHR Conversions

Bob explains how EHR system conversions affect 340B operations and compliance. He walks through the steps his team took before and during one of its conversions and points out the potential pitfalls to avoid.  

Strategies for Managing NDCs 

An EHR conversion means 340B professionals need to be aware of potential NDC challenges that go along with it. Bob shares some questions 340B professionals should ask about charging and administration practices when planning for a change in EHR systems. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources 

1. List of Drugmaker 340B Restrictions Grows in Wake of Court Decision 
2. 340B Insight Episode 67: Maureen Testoni’s Outlook for 340B in 2023
3. 340B Coalition 2023 Winter Conference 

Several 340B developments have occurred in the first weeks of 2023, with many more expected to come this year. In this episode, we speak with 340B Health President and CEO Maureen Testoni about her outlook for 340B. Our discussion includes her analysis of the latest in the 340B contract pharmacy dispute, the 340B advocacy landscape at the federal and state levels, and Medicare issues affecting 340B.

*Editor’s note: We spoke with Maureen prior to Bayer and EMD Serono announcing they will restrict 340B discounts. When these restrictions start in March, at least 21 companies will be limiting 340B discounts, with 14 of these companies conditioning 340B pricing on providers sharing contract pharmacy claims data.* 

U.S. Appeals Court Decision on 340B Contract Pharmacies

Litigation continues on drug companies imposing restrictions on 340B pricing to hospitals and other providers when drugs are dispensed through community and specialty pharmacy partners. Maureen discusses a recent U.S. federal appeals court decision and the next steps in the litigation process. She also explains the trends in the drugmakers’ restrictions.  

2023 Advocacy Landscape for 340B 

Two recent national newspaper stories portrayed 340B in a negative light, but they did not include a complete picture about how 340B works. Maureen discusses what the increased media attention means for 340B advocacy this year and what hospitals should do to advocate for the program. She also shares an overview of 340B legislative activity at the state level.  

Medicare Payment Issues for 340B Hospitals

Maureen shares what she will be watching for during the implementation of a new Medicare drug price-setting law. She also explains the status of repayments to 340B hospitals for unlawful Medicare cuts. 

340B Administrative Dispute Resolution (ADR) Process

HHS has proposed revisions to the ADR process for resolving disputes between covered entities and drug manufacturers over 340B pricing. Maureen examines how these revisions will clarify the process and further changes that 340B hospitals are requesting.

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources 

1. Statement on Third Circuit Appeals Court Decision on Drugmakers’ 340B Restrictions
2. Statement on Bayer and EMD Serono Restricting 340B Discounts Through Community-based Pharmacies 
3. 340B Health Comment Letter to HRSA on Proposed Changes to the 340B Administrative Dispute Resolution 
4. 340B Coalition Winter Conference 2023  

We often receive listener questions about 340B issues and developments that affect professionals in the 340B world. In this episode, we open the listener virtual mailbag and answer some of your questions with help from our 340B Health staff experts. Some of the questions we tackle include queries about mitigating 340B contract pharmacy restrictions, understanding 340B patient definition, analyzing current 340B hospital audit trends, and examining Medicare Advantage payment rates for 340B drugs. 

Mitigating Contract Pharmacy Restrictions 

In response to a listener's question, we discuss ways 340B hospitals can access program savings despite contract pharmacy restrictions. We share data about the amount of 340B savings restored to 340B hospitals when they apply for drug company exceptions.

Hospital 340B Audit Trends 

For one listener question, we recap the most recent data on hospital 340B audit results and identify the most common audit finding.

The Impact of Medicare 340B Payment Policy on Medicare Advantage Rates

A listener asks how Medicare Advantage plans are responding to the restoration of full Medicare Part B payment rates for 340B drugs. We discuss what we know and what remains uncertain.

Check out all our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources

1. 340B Hospitals Report Receiving Full Payments for 2022 Part B Drug Claims After Adjustment Requests 
2. 340B Coalition Winter Conference 2023