Building the Case for Dedicated 340B Program Management
Director, Client Success Executive, Omnicell 340B
The pressures of the last year have underscored the importance of the 340B program and its impact on hospital finances. Within this context, it may seem counterintuitive to ask for an investment in more staff to run your 340B program. Yet, based on our experience with covered entities that have a dedicated 340B program manager versus those that don't, the advantages are worth it. It's important to work with hospital leadership to underscore the importance of this position, and how it will drive program success.
Making a case for a dedicated 340B program manager
There are several advantages to having an intentional set of eyes focused on optimizing your 340B program to identify areas you may otherwise not have time to address. Let's look at five tangible ways your program benefits from having a dedicated 340B program manager who can identify and address those challenges that limit your ability to realize total program value. A dedicated 340B program manager can help you:
- Realize savings faster
Most 340B third-party administrators (TPAs) have standard implementation processes that determine how long it will take to bring a new location or pharmacy live. But there are a number of elements outside the TPA's control that a dedicated 340B program manager can help accelerate, including assisting with TPA contracting, HRSA process and documentation, data requests, and wholesaler agreements, leading to faster implementation.
- Achieve sustainable program optimization
When you have a person dedicated to finding and stopping program leakage, you are likely to uncover strategic opportunities that go beyond the capabilities of your TPA and software. By regularly reviewing top drug volumes and value, top prescribers, top prescribing locations, and non-automated workflows, a 340B program manager may find missed opportunities for 340B value that can be remedied through cross-functional conversations, education, and initiatives. Taking time to sort out the root cause of missed opportunities will enable more 340B-friendly practices across the organization that can result in significant value for your program.
- Account for and recoup losses
We all know that manufacturers can audit your organization on-demand, but who in your organization is monitoring the manufacturers? In light of the bold contract pharmacy actions of 2020, this is an area that is becoming more critical. Depending upon the manufacturer's reason for withholding 340B pricing, you could be entitled to future compensation via legal action or the administrative dispute resolution (ADR) process. You need to track the financial impact of current manufacturer actions and forecast the potential effects of future activities.
- Access manufacturers' best pricing
Another accessible area to overlook is the accuracy and availability of 340B pricing in your wholesaler catalogs. A common reason for pricing discrepancies is that the covered entity has not met a specific manufacturer requirement for a limited distribution drug. But the good news is that the issue can be remedied. If your TPA doesn't do this for you proactively, make it an area of focus for your 340B program manager.
- Eliminate eligible program leakage
No matter how well you align your 340B software configurations, there are likely eligible claims that fall out of your automated processes for one reason or another. But just because these encounters cannot be captured in an automated fashion, it doesn't automatically disqualify them from 340B eligibility. They may simply require a little more effort to create an auditable record. And because these encounters tend to be associated with a high 340B program value, the extra effort is worth it.
With 340B-related news drawing attention to the important role the 340B program plays in hospital finance, there's never been a more opportune moment to champion for a dedicated 340B program manager who can optimize your program and preserve its value. Download our recent eBook to access the tools you need to build a business case around the value of a dedicated 340B program manager.
The views and opinions expressed in this blog are those of the authors and do not necessarily reflect the official policy or position of any other agency, organization, employer, or company. Assumptions made in the analysis are not reflective of the position of any entity other than the author(s). These views are always subject to change, revision, and rethinking at any time and may not be held in perpetuity.