As 340B covered entities continue to struggle financially, here are four program strategies to consider



Jeff Spencer, Senior Vice President, PSG 340B
May 20, 2020

This is part two of a three-part blog series highlighting ways for 340B covered entities to maximize cash flow and savings opportunities during the COVID-19 public health emergency. You can read part one of the series here

To build upon the 340B program-level recommendations we shared with you previously, we are now turning our focus to high-value prescriptions, replenishment and ordering opportunities to optimize cash flow and 340B savings.


Capturing 340B savings through manual claims qualification

Most covered entities have a subset of 340B-eligible claims that fall outside of standard workflows, including:

  • Referral claims that require additional documentation
  • Scripts that require preauthorization
  • Infusion claims with multiple formulations
  • Specialty claims that fall outside of standard date-written windows

Check with your TPA for assistance identifying these claims and holding them for manual review and validation. If the encounters meet qualification requirements, you can still recognize 340B savings after completing additional documentation and approval steps.

 

Prepare your program for an increase in mail order scripts

Even if you’ve previously decided against adding a mail order pharmacy to your contract pharmacy program, you might want to reconsider in light of new patterns emerging as a result of COVID-19. Since March, some entities have noticed a dip in contract pharmacy prescriptions and an increase in mail order utilization as patients and providers adjust to an increase in 90-day prescriptions and mail order fulfillment for their prescriptions. In fact, The Wall Street Journal reports that mail order prescription volume grew 21 percent during the last week of March – a level expected to continue to some degree post-pandemic.

We’re seeing covered entities successfully leverage the immediate registration and eligibility provisions of HRSA’s 340B public health emergency rules during the current pandemic to add new mail order and non-mail order pharmacies. Adding a mail order pharmacy is a critical, immediate step that can help capture traditional contract pharmacy scripts that are moving to this channel. In our first post in this series, we detail the processes for immediate registration and eligibility.

 

Minimizing unnecessary WAC spend

Now is a great time to analyze your top 20 drugs, looking for NDCs with unreplenished 340B accumulations that may have been overpurchased at WAC. You can capture the associated 340B savings on these items simply by placing orders against the eligible accumulations.

 

Negotiating changes to contract pharmacy operational parameters

Some contract pharmacies are open to temporary operational changes that can accelerate the realization of your earned 340B savings during this emergency. While options are pharmacy-dependent and may require a change to your pharmacy services agreement (PSA), some options to consider include:

  • Increasing the frequency of billing to accelerate 340B payments from pharmacies
  • Increasing the frequency of ordering to speed up 340B replenishment and savings
  • Extending the reprocessing window to accommodate replenishment of eligible claims that fall outside of the automatic qualification process
  • Extending the window for true-up to allow more NDCs an opportunity for replenishment in light of drug shortages and supply chain delays

 

Our efforts continue

 As we continue to seek ways to maximize the financial impact of your 340B program, we will be turning our attention next to opportunities such as automating qualifications within certain drug therapy classes or locations and navigating missing 340B pricing in wholesaler catalogs. In addition, for a look back at the recommendations included in our last blog, click here.

Unprecedented times call for unprecedented collaboration to meet the challenges you’re facing. The work you do is even more valuable in these times, and we are here to support you.

 



Jeff Spencer is an experienced consultant in the pharmacy healthcare industry with special expertise in 340B drug programs, health system pharmacy strategies, employee benefit integration, data analysis, program benchmarking, and development of custom client deliverables such as executive-level reports and financial projections.