Cindy Kehr Director of Purchasing & Pharmacy Services Keystone Rural Health Center

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1 Cindy Kehr Director of Purchasing & Pharmacy Services Keystone Rural Health Center

2 Statement of Conflicts of Interest Cindy Kehr has no actual or potential conflict of interest in relation to this presentation. 2

3 Today s Agenda In house Pharmacy and Contract Pharmacy Inventory Management Virtual Inventory National Drug Code (NDC) 11 digit Replenishment 3

4 CE Question The Office of Pharmacy Affairs (OPA) does not require there be an exact match between the drug used and the replenished drug. A) True B) False 4

5 Keystone Health Founded in 1986 Only federally qualified Community Health Center serving Franklin County 11 Entity sites 172,500 annual patient encounters serving 44,800 patients 50,000 annual in house prescriptions 36,000 annual contract pharmacy prescriptions Carve out Medicaid 1 in house pharmacy and 9 contract pharmacies 5

6 In House & Contract Pharmacies Our in house pharmacy is located in the building with four of our practices. We have nine contract pharmacies located throughout Franklin County. Our pharmacies fill prescriptions for clinic and non clinic patients as well as third party and sliding fee patients. Our Goals are to: Provide patients affordable access to medications Manage the financial aspects of the pharmacy services Improve patient health 6

7 Perpetual vs Virtual Inventory Virtual Inventory Simplifies 340B inventory and 340B inventory management for the pharmacies and the CHC Inventory Management Utilize a third party administrator (accumulator, reports & database) Patient database is updated daily by the entities and reviewed monthly by the 340B staff (prevent diversion) 340B claims are captured based on eligible provider and patient eligibility in the database Inventory is replenished when a full package size is reached CHC staff processes 340B replenishment orders NDC 11 digit to NDC 11 digit 7

8 340B Replenishment NDC 11 digit to NDC 11 digit The covered entity is responsible for compliance Pitfalls of 340B Virtual Inventory Reduces 340B savings for the covered entity and has potential for 340B inventory to be on the pharmacy shelf. Slow movers Substitutions Packaging changes resulting in new NDC 11 digit Reversals Duplicates (claims) Secondary Payors Obsolete Inventory Large Quantity Bottle Sizes 8

9 Inventory Unable to be Replenished Slow Movers, Substitutions, Packaging Changes, Large Quantity Bottle Sizes & Obsolete Inventory Sliding Fee Patient pays $16.89 for a script Health Center has to reimburse Contract Pharmacy at a Network Rate $ Health Center loses approximately $

10 Inventory Owned by the Health Center Reversals Claim processed for 30 tablets; inventory replenished to the contract pharmacy by the Health Center Patient doesn t pick up the medication; claim is reversed and put back into inventory Health Center now owns the inventory on the shelf at the contract pharmacy Work with the contract pharmacy to return the inventory owned by the Health Center to the wholesaler Send third party administrator documentation of the return in order for the inventory to be adjusted accordingly 10

11 Inventory Owned by the Health Center Duplicate Claims & Secondary Payors To avoid over replenishment to the contract pharmacy it is important to review all claims data Review reports for duplicate claims; claims with the same fill date, the same quantity and the same drug Review reports for claims with a primary and secondary payor 11

12 CE Question The Office of Pharmacy Affairs (OPA) does not require there be an exact match between the drug used and the replenished drug. A) True B) False 12

13 CE Question & Answer The Office of Pharmacy Affairs (OPA) does not require there be an exact match between the drug used and the replenished drug. A) True B) False OPA requires that there be an exact match between the drug used and the replenished drug using the National Drug Code (or NDC, which is issued by the FDA and specifies drug identity, package size and manufacturer). 13

14 Additional Questions? Cindy Kehr Director of Purchasing & Pharmacy Services Keystone Rural Health Center 755 Norland Avenue, Suite 200 Chambersburg, PA Phone: