Eight ways 340B covered entities can maximize cash flow and savings during the COVID-19 public health emergency

The impact of COVID-19 on hospital and clinic finances has been fierce and immediate, making the 340B program more important than ever to covered entities struggling to remain in the black while experiencing reduced revenue from elective procedures. Over the last few weeks, PSG has assembled a team of financial, operational and pharmacy experts to identify best practices our clients can use to optimize their 340B program for immediate operational efficiencies, cash flow enhancement and savings. As we work with each of our clients to roll out these recommendations in a phased approach, we also wanted to offer them here for the benefit of additional covered entities.

Here’s where we suggest you start:

COVID-19 best practices

If you haven’t already, review any changes to your 340B program resulting from the current public health emergency and align your 340B policies and procedures accordingly. Then, work with your 340B third-party administrator (TPA) to identify and implement configuration and operational changes needed to align your 340B solution to your current reality. Here are some items you’ll want to consider addressing immediately in order to realize the maximum benefit to your 340B program:

• Ensure that your current list of providers includes all currently contracted, temporary, volunteer and on-staff providers – including those who may be “floating” from another location.
• Evaluate your record-keeping practices for patient eligibility in light of your emergency procedures. Can you continue to meet compliance requirements while temporarily switching to a doctor-only match?
• Ensure your 340B policies and procedures accurately reflect your current telemedicine practices.
• Review your GPO purchasing practices in light of recent guidance allowing GPO purchasing for drugs in short supply.

Immediate registration and eligibility

As you are likely aware, HRSA is allowing immediate registration and eligibility for new sites and pharmacies on a case-by-case basis. We recommend you review eligibility for all field hospitals, child sites, relocated departments, clinics and pharmacies affected by your organization’s response to COVID-19 and request immediate accommodations as appropriate.

For all eligible locations:

1. Review your registrations in the OPAIS database to identify any current service areas that are unregistered, and request immediate registration and eligibility through Apexus (1-888-340-2787 or [email protected]). Apexus will require the following details to proceed with your request:
   • Medicare provider number
   • 340B ID entity name
   • Subdivision name
   • Site address
   • AO and PC name and email address
   • Emergent Issue for immediate start date
2. If newly-registered locations from the April registration period are still awaiting July 1 eligibility, request immediate eligibility through Apexus.
3. While temporarily-relocated service areas do not require new registration as long as the temporary adjustment is noted in your 340B policies and procedures, we strongly encourage you to contact Apexus to notify them of the change.

For new pharmacy locations, including mail order and specialty:

Covered entities that can demonstrate a COVID-19 need for immediate registration and eligibility of new pharmacy locations are having success pursuing this strategy through Apexus, provided they have a contract pharmacy agreement in place. For this reason, we recommend the following actions:

1. Request immediate eligibility for all new pharmacies registered during the April registration period. This will allow your program to benefit from all eligible scripts written from the eligibility date forward, as soon as these locations are live. Be prepared to describe the urgency for the request and how it relates to COVID-19.
2. Consider whether new prescribing and refill patterns resulting from COVID-19 justify the addition of new retail, specialty or mail order pharmacies, and request immediate registration and eligibility for those you need to add.

Since new eligibility dates are dependent upon when the request is submitted, we recommend you request these changes as soon as possible.

Enbrel, Repatha and other NDC-level opportunities

Enbrel and Repatha are two products that recently experienced changes in NDCs for the exact same drug, dose, formulation and/or volume. While unusual, HRSA has issued notices specifically allowing for unreplenished 340B accumulations of the original NDCs to be replenished with the new NDCs for both Enbrel and Repatha. Several of our clients have seen a material 340B savings impact by replenishing previously-unreplenished 340B accumulations of these high-value products. We recommend you reach out to your 340B TPA and your contract pharmacies to coordinate this process.

Enroll in the COVID-19 Uninsured Program

While not specifically 340B-related, you are likely affected by the COVID-19 Uninsured Program included as part of the legislative response to COVID-19. Health and Human Services is providing reimbursement at Medicare rates for COVID treatment testing and treating for uninsured patients with COVID-19 diagnoses on or after February 4, 2020. HHS began accepting claims electronically on May 6, and reimbursements will begin in mid-May. To ensure you are able to submit eligible claims as soon as possible, visit the COVID-19 Uninsured Program Portal to learn more and enroll: https://coviduninsuredclaim.linkhealth.com/

What’s next?

In the next installment of this three-part blog series, we’ll highlight additional strategies we’re pursuing to improve cash flow and capture of eligible 340B savings. It will provide details on specific actions you can take to benefit your program, including:

• Pursuing purchasing opportunities that may improve 340B savings from your top 20 drugs by cost
• Manually qualifying high-value claims
• Working with your contract pharmacies to negotiate temporary operational exceptions, including more frequent billing, extended reprocessing window and longer true-up times

If you’re missing any eligible 340B savings for your program, we want to help you find it.

On behalf of the invaluable services you provide to your community, you can count on PSG to be your relentless advocate. We are committed to delivering tangible benefit to our clients as we face these new challenges, and we look forward to sharing our recommendations with all who can benefit. Working together, we can help ensure the continued strength of your 340B program and the financial viability of your organization.

For more cash flow and 340B savings ideas, be sure to read part two of our blog series, where we address manually qualifying 340B claims, preparing your program for a shift to mail order, minimizing unnecessary WAC spend and temporarily adjusting operational parameters with your contract pharmacies.