Chargeback Adjudication for 340B Contract Pharmacies

Transcription

1 Chargeback Adjudication for 340B Contract Pharmacies June 21 st 2017 Kunal Akwalia, Senior Manager, Highpoint Solutions Agenda Key Terms Impactful Challenges Current State Other Considerations What information is available Twice is nice, or is it? Other players: IDNs and Central Purchasing Pharmacies 2 1

2 Key Terms 340B Program Covered Entity 340B Price Eligible Patient Contract Pharmacies 340B Refund Orphan Status PHS Sub Categories 3 Impactful Challenges Managing 340B contracts is possible, but failure to do so in a compliant manner can have significant downstream impacts. Notably, Selling product at 340B price points to non covered entities can impact Best Price Implications of duplicate discounts Managing and administration of 340B refunds has challenges 4 2

3 Current State Master Data Management Names Customers Address DEAs Identifiers 340B General COT Class of Trade PHS Sub Category Relationships Single bill to with many ship to sites Maintenance Roster Loading 5 Current State Contracting Pricing Having the right AMP, URA, CPI U and other components calculated in order to forecast the 340B price is burdensome. Despite the many resources and conferences out there, sometimes 340B price has to be recalculated. Eligibility Should you proactively notify the wholesaler which 340B contract pharmacies entities can purchase product on the 340B contract? Should you follow a reactive model that allows your team the time to assess the chargeback to determine if the sale is valid and 340B compliant? 6 3

4 Current State Payment Processing Contract Compliance Chargeback Loading Bill to / Ship to alignment Processed Chargeback Payments 7 Other Considerations Visibility With so many stops along the way it is difficult to follow a product from wholesaler purchase to patient claim Volume Good news: sales are booming for pharma/biotech Bad news: way too many sales to analyze in a time efficient manner Maintenance Roster management isn t as clear as water, in fact it s murky at best. 8 4

5 Working with what we have 340B/PHS ID PHS Sub Categories PHS Contract Pharmacy Alignment 9 Twice is nice, or is it? Dollars and Sense Is someone pulling the wool over your eyes? The existence of duplicate discounts isn t limited to chargebacks Let s count the discounts 340B chargebacks Medicaid MFR Chbk, Days later Sale to WHL WHL Sale to IDN / GPO / CPP Claim, Months Later IDN / GPO / CPP Sale to Covered Entity Sale to Contract Pharmacy Sale to Retail Chain Prescription / Dispense to Patient Claim to Medicaid Processer Medicaid Processer Claim to Manufacturer Copyright HighPoint Solutions, LLC. All Rights Reserved. Unauthorized Distribution or Duplication Prohibited. 10 5

6 Other players: IDNs, Central Purchasers Integrated Delivery Networks (IDNs) and CPPs can create challenges Let s paint the picture: While the central purchasing pharmacy may have been compliant with the 340B program, what about the others? Primary Wholesaler/ Distributor Secondary Tertiary Central Purchasing Pharmacy Site #1 Site #2 IDN Site #3 11 In Summary Processing 340B Chargebacks has its challenges Pricing alignment Contract verification Customer validation Product Tracing Identification of Duplicate Discounts Continue current state processing Continue dialogue with Covered Entities, Medicaid Programs 12 6

7 THANK YOU Any Questions? 7