#340B Third Party Administrator

[veritysolutions-blog]

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:

Split Billing

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.

A fully managed service

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.

Purchase analytics

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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[mariebenz]

Safety Net Hospital Earn Modest Profit from Medicare's Discount Drug Program

MedicalResearch.com Interview with: Dr. Conti Rena M. Conti, PhD, Associate Professor Department of Markets, Public Policy and Law Questrom School of Business Boston University Boston, MA 02215 Co-Authors: Sayeh S. Nikpay, PhD Melinda B. Buntin, PhD Vanderbilt University School of Medicine MedicalResearch.com: What is the background for this study? Response: The federal 340B program provides deep discounts on the acquisition cost of prescription drugs for participating hospitals and places no limits on what hospitals charge patients and insurers.  Congress intended 340B profits generated from hospital participation to subsidize the provision of safety net care for patients residing in the community. This study is the first to estimate the size of profits hospitals participating in the 340B drug discount program collect from Medicare patients for the outpatient clinic administration of prescription drugs. MedicalResearch.com: What are the main findings? Response:  In 2016, hospitals reaped a total of $1.9B in profit from administering 340B-discounted drugs to Medicare patients.  Per hospital mean 340B profits amounted to $2.5M.  340B profits are small in terms of overall hospital budgets but significant compared to at least one measure of safety net care provided to their communities. There is considerable state to state variation in hospital 340B participation, the profits reaped from 340B and hospital safety net care provision. MedicalResearch.com: What should readers take away from your report? Response: More than half of all hospitals in the U.S. profit from the outpatient administration of prescription drugs to seniors.  These profits are significant relative to the value of safety net care hospitals provide to their communities. MedicalResearch.com: What recommendations do you have for future research as a result of this work? Response: To comprehensively assess the value of 340B to participating hospitals, data on the profits reaped from sources beyond prescription drugs administered to seniors are needed.  Future research should systematically examine the impact of 340B profits on the benefits hospitals provide to their communities. Any disclosures? This work was funded by a grant from the Commonwealth Fund. Citation: Conti RM, Nikpay SS, Buntin MB. Revenues and Profits From Medicare Patients in Hospitals Participating in the 340B Drug Discount Program, 2013-2016. JAMA Netw Open. Published online October 30, 20192(10):e1914141. doi:10.1001/jamanetworkopen.2019.14141 Last Modified:       The information on MedicalResearch.com is provided for educational purposes only, and is in no way intended to diagnose, cure, or treat any medical or other condition. Always seek the advice of your physician or other qualified health and ask your doctor any questions you may have regarding a medical condition. In addition to all other limitations and disclaimers in this agreement, service provider and its third party providers disclaim any liability or loss in connection with the content provided on this website.   Read the full article

[kristinsimmons]

Are Bipartisan Agreements on Health Care Possible?

By KEN TERRY 

Republicans and Democrats are seen as poles apart on health policy, and the recent election campaign magnified those differences. But in one area—private-sector competition among healthcare providers—there seems to be a fair amount of overlap. This is evident from a close reading of recent remarks by Health and Human Services Secretary Alex Azar and a 2017 paper from the Brookings Institution.

Azar spoke on December 3 at the American Enterprise Institute (AEI), the conservative counterpart to the liberal-leaning Brookings think tank. Referring to a new Trump Administration report on how to reduce healthcare spending through “choice and competition,” Azar said that the government can’t just try to make insurance more affordable while neglecting the underlying costs of care. “Healthcare reform should rely, to the extent possible, on competition within the private sector,” he said.

This is pretty close to the view expressed in the Brookings paper, written by Martin Gaynor, Farzad Mostashari, and Paul B. Ginsburg. “Ensuring that markets function efficiently is central to an effective health system that provides high quality, accessible, and affordable care,” the authors stated. They then proposed a “competition policy” that would require a wide range of actions by the federal and state governments.

The major difference between Azar and the Brookings experts is that Azar blames government regulation and they blame the consolidation of healthcare systems, most of all, for the relative lack of competition in healthcare markets. The parties agree, however, that healthcare prices are primarily responsible for driving up costs. U.S. healthcare spending rose from 2012 to 2016, Azar said, not because of higher utilization, but because of higher prices.

Azar favors consumer-driven plans coupled with health savings accounts to give patients an incentive to seek value and thereby reduce costs. But, while these plans have reduced unnecessary spending in the private market, he said, they haven’t been a silver bullet for private-sector employers that have used them. These plans can reduce unnecessary spending, but financial incentives for patients won’t build a truly competitive market, he said.

What’s needed, in his view, is less government regulation that drives provider prices up. For example, he said, CMS’s hospital outpatient payment system had impeded competition by paying hospital-owned practices more than private practices for the same services. He praised CMS for switching to site-neutral payments for all services offered by both hospital-employed and private practice physicians.

The Brookings experts supported the same regulatory change before CMS made it. In their report, they also said that states should repeal certificate-of-need laws, which inhibit new market entrants. And they favored reforming the 340b drug discount program for hospitals, which they said encouraged the facilities to employ physicians, especially oncologists who administer very expensive drugs. (CMS recently lowered those discounts by nearly 30%.)

Consolidation most to blame

However, the Brookings experts emphasized the role of industry consolidation in the steep rise of healthcare prices. Noting that these prices vary tremendously across the country, the report authors said that market power drives much of this variation. “Hospitals with little effective competition can extract higher prices in their negotiations with insurers, and they do,” they noted. “Hospitals without local competitors are estimated to have prices nearly 16 percent higher on average than hospitals with four or more competitors, a difference of nearly $2,000 per admission.”

Mergers of insurance companies have also driven up health costs, the paper said. The market share of the top four national insurers grew from 74% in 2006 to 83% in 2014. In the median state, the two largest carriers now control two-thirds of the market.

But that horse is out of the barn—and in any case, insurers don’t have much choice but to accede to the dominant healthcare providers in some markets. So the Brookings competition proposal focuses mainly on what can be done to increase competition among providers.

Among their more significant proposals, the Brookings experts would:

Have federal and state agencies increase antitrust scrutiny of horizontal and vertical healthcare mergers

Ask Congress to pass legislation allowing the Federal Trade Commission (FTC) to enforce antitrust laws on healthcare providers and insurers

Revise the Medicare Shared Savings Program (MSSP) regulations to limit the influence of large hospitals and health systems over accountable care organizations (ACOs)

Neither the Brookings paper nor Azar talked about taking two other steps that could promote healthcare competition: 1) liberate doctors from the grip of hospitals; and 2) replace competition between insurers with competition between physician-led entities, such as ACOs and primary care-oriented medical groups. But those radical changes would be impossible without universal health coverage, and it’s unlikely that Congress will vote for that unless Democrats win back the Senate and the White House in 2020.

In a recent Health Affairs forum on health policy ideas for 2020 Presidential candidates, the liberal and conservative panelists agreed that Congress is not likely to do much on healthcare in the next two years. But in the area of competition, perhaps the left and the right can work together on some reforms if they don’t get into a tussle over Medicare for All. Some kind of legislation to lower drug prices is already in the air, and it looks like the two parties could also have a meeting of the minds on promoting competition in healthcare.

The Democrats aren’t going to suddenly support consumer-driven plans, which they view as discriminating against poor and sick people. But perhaps they might be open to changes in the Stark and AKA regulations to allow market-based innovations, and they might be willing to encourage states to throw out certificate-of-need laws. Similarly, the Republicans won’t be thrilled about the idea of a massive antitrust crackdown on healthcare mergers. But they might let CMS release practice-level cost and quality data that can help ACOs form networks and help consumers choose providers.

At least the two sides seem to agree on one thing: Only real competition among providers can constrain healthcare spending.

Ken Terry is a former senior editor of Medical Economics and is author of Rx For Healthcare Reform (Vanderbilt University Press, 2007).

Are Bipartisan Agreements on Health Care Possible? published first on https://wittooth.tumblr.com/

[isaacscrawford]

Are Bipartisan Agreements on Health Care Possible?

By KEN TERRY 

Republicans and Democrats are seen as poles apart on health policy, and the recent election campaign magnified those differences. But in one area—private-sector competition among healthcare providers—there seems to be a fair amount of overlap. This is evident from a close reading of recent remarks by Health and Human Services Secretary Alex Azar and a 2017 paper from the Brookings Institution.

Azar spoke on December 3 at the American Enterprise Institute (AEI), the conservative counterpart to the liberal-leaning Brookings think tank. Referring to a new Trump Administration report on how to reduce healthcare spending through “choice and competition,” Azar said that the government can’t just try to make insurance more affordable while neglecting the underlying costs of care. “Healthcare reform should rely, to the extent possible, on competition within the private sector,” he said.

This is pretty close to the view expressed in the Brookings paper, written by Martin Gaynor, Farzad Mostashari, and Paul B. Ginsburg. “Ensuring that markets function efficiently is central to an effective health system that provides high quality, accessible, and affordable care,” the authors stated. They then proposed a “competition policy” that would require a wide range of actions by the federal and state governments.

The major difference between Azar and the Brookings experts is that Azar blames government regulation and they blame the consolidation of healthcare systems, most of all, for the relative lack of competition in healthcare markets. The parties agree, however, that healthcare prices are primarily responsible for driving up costs. U.S. healthcare spending rose from 2012 to 2016, Azar said, not because of higher utilization, but because of higher prices.

Azar favors consumer-driven plans coupled with health savings accounts to give patients an incentive to seek value and thereby reduce costs. But, while these plans have reduced unnecessary spending in the private market, he said, they haven’t been a silver bullet for private-sector employers that have used them. These plans can reduce unnecessary spending, but financial incentives for patients won’t build a truly competitive market, he said.

What’s needed, in his view, is less government regulation that drives provider prices up. For example, he said, CMS’s hospital outpatient payment system had impeded competition by paying hospital-owned practices more than private practices for the same services. He praised CMS for switching to site-neutral payments for all services offered by both hospital-employed and private practice physicians.

The Brookings experts supported the same regulatory change before CMS made it. In their report, they also said that states should repeal certificate-of-need laws, which inhibit new market entrants. And they favored reforming the 340b drug discount program for hospitals, which they said encouraged the facilities to employ physicians, especially oncologists who administer very expensive drugs. (CMS recently lowered those discounts by nearly 30%.)

Consolidation most to blame

However, the Brookings experts emphasized the role of industry consolidation in the steep rise of healthcare prices. Noting that these prices vary tremendously across the country, the report authors said that market power drives much of this variation. “Hospitals with little effective competition can extract higher prices in their negotiations with insurers, and they do,” they noted. “Hospitals without local competitors are estimated to have prices nearly 16 percent higher on average than hospitals with four or more competitors, a difference of nearly $2,000 per admission.”

Mergers of insurance companies have also driven up health costs, the paper said. The market share of the top four national insurers grew from 74% in 2006 to 83% in 2014. In the median state, the two largest carriers now control two-thirds of the market.

But that horse is out of the barn—and in any case, insurers don’t have much choice but to accede to the dominant healthcare providers in some markets. So the Brookings competition proposal focuses mainly on what can be done to increase competition among providers.

Among their more significant proposals, the Brookings experts would:

Have federal and state agencies increase antitrust scrutiny of horizontal and vertical healthcare mergers

Ask Congress to pass legislation allowing the Federal Trade Commission (FTC) to enforce antitrust laws on healthcare providers and insurers

Revise the Medicare Shared Savings Program (MSSP) regulations to limit the influence of large hospitals and health systems over accountable care organizations (ACOs)

Neither the Brookings paper nor Azar talked about taking two other steps that could promote healthcare competition: 1) liberate doctors from the grip of hospitals; and 2) replace competition between insurers with competition between physician-led entities, such as ACOs and primary care-oriented medical groups. But those radical changes would be impossible without universal health coverage, and it’s unlikely that Congress will vote for that unless Democrats win back the Senate and the White House in 2020.

In a recent Health Affairs forum on health policy ideas for 2020 Presidential candidates, the liberal and conservative panelists agreed that Congress is not likely to do much on healthcare in the next two years. But in the area of competition, perhaps the left and the right can work together on some reforms if they don’t get into a tussle over Medicare for All. Some kind of legislation to lower drug prices is already in the air, and it looks like the two parties could also have a meeting of the minds on promoting competition in healthcare.

The Democrats aren’t going to suddenly support consumer-driven plans, which they view as discriminating against poor and sick people. But perhaps they might be open to changes in the Stark and AKA regulations to allow market-based innovations, and they might be willing to encourage states to throw out certificate-of-need laws. Similarly, the Republicans won’t be thrilled about the idea of a massive antitrust crackdown on healthcare mergers. But they might let CMS release practice-level cost and quality data that can help ACOs form networks and help consumers choose providers.

At least the two sides seem to agree on one thing: Only real competition among providers can constrain healthcare spending.

Ken Terry is a former senior editor of Medical Economics and is author of Rx For Healthcare Reform (Vanderbilt University Press, 2007).

Article source:The Health Care Blog

[4rhealth]

Health Care Swindle: What Is Your Medical Bill Concealing?

Efforts in Congress to make health care pricing more transparent for consumers need your support. Action Alert!

Lawmakers in the Senate are in the midst of creating legislation intended to make health care pricing more transparent. It is imperative that they hear from consumers—and not just industry cronies—about the importance of transparency.

It’s no mystery that American health care is a crony capitalist mess. In many ways, this is because we treat health care differently than almost every other service. When we visit a mechanic, we are told in advance what we can expect to pay. This is not the case in health care. Rather, we go to the hospital or to a doctor when we’re sick and, too often, are presented with bills full of complex codes that help conceal outrageous costs: $10 for an aspirin; $300 for a single X-ray; $8,000 for an emergency room visit.

Part of the reason consumers are so powerless in these situations is because there is very little transparency in health care pricing. We don’t know the price of a service until we see it on the hospital bill. For this reason, we recently supported legislation in the House of Representatives that would require hospitals, physicians, pharmacies, dentists, health insurers, and other entities offering healthcare services to disclose the price for their products and services at the point of purchase and list prices online. This reform would help drive down costs, since healthcare providers that gouge consumers would lose out to those charging a fair price. It’s the basic economic principle of competition.

A similar effort is taking shape in the Senate. A bipartisan group of senators including Bill Cassidy (R-LA), Michael Bennet (D-CO), Chuck Grassley (R-IA), Tom Carper (D-DE), and Claire McCaskill (D-MO) are spearheading an effort to increase price transparency in health care.

There is no bill as of yet; the senators are in the midst of soliciting feedback from a wide variety of professional associations on how best to achieve the goal of greater transparency. We hope the senators receive honest answers, but we won’t hold our breath. In our view, groups like the American Hospital Association and the American Medical Association profit from consumer confusion.

An additional bill from Sen. Grassley seeks to introduce transparency into the 340B drug pricing program. The program requires drug makers to provide drugs at discounted prices to qualifying hospitals and other entities. As the law currently stands, however, there is no requirement for participating hospitals to report how much patients are charged for discounted drugs. Sen. Grassley’s bill requires hospitals to report to HHS the total acquisition costs for drugs collected through the 340B program, as well as revenues received from all third-party payers for those same drugs.

While it’s a good idea to see if hospitals are profiting at the expense of 340B, we think such reports should be made public and not just to HHS, which might continue to hide the information from consumers.

Transparency in health care pricing also seems to have the backing of the Trump administration. In a speech describing the administration’s proposal for value-based health care, Health and Human Services Secretary Alex Azar highlighted the importance of price transparency as a missing feature of the US health system. One part of Azar’s speech seems to hint at an executive order: “So this administration is calling on not just doctors and hospitals, but also drug companies and pharmacies, to become more transparent about pricing and outcomes of their services and products. And if that doesn’t happen, we have plenty of levers to pull that would help drive this change.”

It’s time we apply some common sense to health care policies in this country, starting with basic economic principles.

Action Alert! Write to Congress and urge them to support transparency in health care pricing—including a message on Sen. Grassley’s bill that 340B reporting should be made public, not just to HHS. Please send your message immediately.

from The Alliance for Natural Health http://ift.tt/2tVa3yO via Aloe for Health