340B Overview by Verity Solutions - www.verity340B.com
Verity 340B Solutions: Manage your 340B Program and stay compliant with Verity 340B Solutions
The 340B Drug Pricing Program provides big benefits to healthcare providers and patients. But it also comes with its own set of challenges. With increasing complexity and demand for audit preparedness, covered entities are having a tougher time managing the program and staying compliant. It’s now more important than ever to have the right solution and the right partner to help your organization stay on top of 340B. That’s where Verity Solutions comes in. At Verity we can help you maximize the performance and agility of your 340B program with a host of product offerings designed to help you foster compliance, respond quickly to changing regulations and maximize your savings. Hundreds of health systems rely on Verity 340B products to maintain compliance, maximize savings, minimize WAC spend and keep them up-to-date with ever-changing rules and regulations.
What 340B is and how it works
Before we get into how Verity Solutions can help companies optimize and remain compliant with 340B, let’s look go over exactly what the program entails. In 1992, the US Federal Government created the 340B Drug Pricing Program. It requires drug manufacturers, through the signed Pharmaceutical Pricing Agreement (PPA) with the secretary of the Department of Health and Human Services (HHS) specified under Section 340B, to provide discounts on outpatient drugs to select safety net providers or eligible health care organizations and covered entities, including Federally Qualified Health Centers. This is to serve the nation’s most vulnerable patient populations. It is made to promote quality assurance and access to affordable medications.
Drugs with the discounted prices can either be available through the respective covered entity’s wholesaler or another channel dependent on the manufacturer. Covered entities can give drugs that they have bought under 340B through to any eligible patient no matter what their payer status or whether the drug is for clinical use or to be self-administered.
Furthermore, manufacturers are expected to offer bigger discounts on single-source and brand-name drugs with generic competition if their best price for a drug is less than the AMP minus 23.1% or if the drug has increased more quickly than the rate of inflation.
How Can Companies Remain Compliant with the Program?
For companies treated as covered entities under the 340B program, it is imperative to provide the kind of quality care patients deserve. With the 340B program, covered entities can give this at a much affordable price. However, any infraction of the rules could lead to penalties that are not only costly but bad for the reputation of the company as well. To avoid this, here are four key elements for companies to remain compliant with the program:
1. Patient Eligibility – It is a must to ensure the eligibility of a patient accepting the discounted outpatient drugs. 340B products must not be given to non-qualifying patients. It is illegal for covered entities to sell and distribute medications under the 340B program to those who are not considered as patients.
2. Anti-Diversion – To ensure that the dispensing of discounted outpatient drugs under the 340B Program is within the rules, companies or covered entities must have an inventory or an audit trail to trace the purchase and pick-up by the patient. The 340B Program regulates the prohibition of diversion of these drugs to non-patients, ineligible facilities within the same facility, and excluded services of the covered entity. Other potential diversion risk areas include security and theft risks.
3. Medicaid Pricing Requirements – Section 340B requires the invoice price to be reflected the acquisition cost plus State approved fees at the time of purchase. It should be noted that dispensing fees and other billing calculation factors might vary by state.
4. Double-Dipping – This complies with the “Double-Dipping” Prohibition of the State Medicaid Cost Rebate Verification. Covered entities must report outpatient pharmacy Medicaid provider numbers to prevent double dipping of rebate. “Double-dipping” happens when a state seeks a Medicaid rebate on the same unit of drug that a manufacturer sold to the covered entity at a discounted price under the 340B program.
The 340B Program’s double-dipping prohibition places obligations on both the covered entity and the state to ensure that, with respect to 340B drugs dispensed to Medicaid beneficiaries, the manufacturer incurs either the 340B discount at the time of the covered entity’s purchase or a later Medicaid rebate to the state, but not both.
Verity 340B helps organizations stay compliant
Our software has the following features that help to ensure that covered entities remain 340B compliant at all times.
Verity Solutions 340B Audit and Compliance Services
HRSA regularly audits covered entities to monitor 340B compliance, which requires those entities to adhere to program regulations and guidelines. With Verity Solutions 340B Audit and compliance services, you can spend less time worrying about them. Our experts simplify your compliance with an end-to-end audit program that includes:
Verification of eligibility (including GPO and outpatient clinic eligibility
A review of relevant policies and procedures and how they are utilized in your organization
Verification of your internal controls to prevent duplicate discounts
A compliance review of your contract pharmacy relationships.
We can even be on-site to help you through HRSA and manufacturer audits every step of the way.
Verity Solutions 340B Compliance Manager
HRSA audits are increasing in frequency and scope and today’s auditors are applying even more pharmacy expertise to their reviews. As a result, covered entities are more at risk for costly remediation and removal from the 340B program than ever before. You need absolute certainty that you have a reliable compliance framework and tracking tools to ensure consistent implementation of your policies and procedures across your organization. Our web-based compliance portal stores your program documentation and gives you the tools to fulfill your self-audit requirements quickly and easily, regardless of which 340B administrator you use.
Verity Solutions Compliance Manager features include
A comprehensive library of compliance tasks and policies written by 340B experts with recommended activities and templates, assessment steps and review criteria
Notifications that tell you where tasks are at, who’s doing them and when they are due, and inform you on their unique risk factors.
Executive reports and metrics
A user-friendly dashboard with compliance information at a glance.
With Verity Solutions 340B Compliance Manager, maintaining your 340B program compliance has never been easier.
Verity 340B helps covered entities save even more money
Our solutions can also help covered entities save money and improve their process thanks to these features:
Verity Solutions Split Billing can simplify your 340B program and optimize your savings for qualified transactions while helping you maintain compliance. Every covered entity can benefit from our solution as it is compatible with all major wholesale vendor order-entry and hospital information systems. You can automatically split replenishment orders for medications into as many accounts as necessary to meet your individual needs and match pharmaceutical usage with wholesale order quantities to maximize savings. Access on-demand reports, dashboards and application tools for full visibility into your 340B program and innovative features like best price logic, CDM mapping alerts, package size recommendation tools and central distribution support. Ultimately, it helps to simplify your order process and eliminate the need for labor-intensive separate invoices.
With the Verity Solutions 340B managed services offering, our dedicated experts can help you manage your 340B program using our advanced software platform. Our team will help you take advantage of every possible saving opportunity while maintaining full compliance and audit readiness. Our team will manage the key details of your 340B program so you don’t have to. As a result, we can help you maximize savings and minimize WAC spend. Don’t think you won’t know what’s going on, however. Our reports, dashboards and application tools provide full visibility into your 340B program. With our managed service, you can rest assured that your 340B software is up-to-date with the latest compliance regulations.
Contract pharmacy program
Under the 340B Drug Pricing Program, you can partner with pharmacies within your community to dispense eligible prescriptions on your behalf, which lets your organization access additional savings while providing patients with convenient access to the drugs they need.
Establishing and maintaining these relationships is a complex task. That’s where Verity 340B comes in. Our contract pharmacy makes it easy. We help you engage and recruit new pharmacies on your behalf. We’ll then work with these retail pharmacies to obtain proper registration with the Office of Pharmacy Affairs. We can also maximize your capture rate of eligible and profitable prescriptions, provide an ordering interface which gives your pharmacies more control and more visibility into 340B drug replenishments with no more unexpected deliveries or inventory swell. We also offer an enterprise view so that you can access data across your participating locations and provide reports tools and dashboards to give you a complete audit-ready view into your program performance and activity. If you want to take things further, you can leverage Specialty Contract Rx, our preferred Specialty and Infusion partnerships.
Annual hospital drug spending is rapidly increasing, this trend continues to negatively impact hospital costs, especially since Medicaid reimbursement isn’t keeping up. Verity Solutions purchase analytics platform can help. With purchase analytics, you can proactively monitor and analyze NDC pricing opportunities, enabling you to identify the optimal NDCs for significant savings. Purchase analytics provides your organization with savings regardless of which 340B wholesaler or administrator you use. It’s cloud-based, so there’s no software to download or maintain, it features built-in price trends and requires minimal staff resources to operate. With over 100,000 NDCS is impossible for covered entities to do an analysis manually. With the exception of a few high-value drugs, typically a buyer would purchase the cheapest GPO product, but is that really the best choice? With purchase analytics, you can identify a blended price and establish which NDC is the most cost effective for your organization. Remember the 340B price is not directly related to the GPO price. Purchase analytics helps you identify the lowest available drug prices based on your utilization. With purchase analytics, you can achieve savings of 10-13% across your total drug spend.
Verity Solutions would like to extend an invitation to visit us at the following websites to learn more about us and our 340B Third Party Administrator Services.
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