The year 2020 blurred into 2021, leaving healthcare systems hoping for a better year on the horizon. However, 2021 brought no such relief as challenges continued to present themselves as the year went on. Not only did we head into the year still battling COVID-19, but we also began to see the domino effect that started with Eli Lilly’s first 340B policy change. More manufacturers continued to follow suit and it became more important than ever to start rethinking the way 340B programs were structured.
January 2021 kicked off the year with lawsuits filed by Eli Lilly, Sanofi, and AstraZeneca, in hopes to reverse the advisory opinion released by HHS just one month earlier. From there, it has been a whirlwind of motions and litigations, that to this day, are still underway.
With all this buzz in the 340B world, Covered Entities have made it a priority to advocate for their health centers, their 340B programs, and their patients. They have focused their efforts on navigating contract pharmacy designations, optimization, and creating access. Pharmacy designations are not simple by any means. Instead, it has taken coordination with multiple vendors and time to ensure that all the steps were completed, and the 340B pricing restored for all designations However, Entities have remained diligent and dedicated to doing what they can to regain access to life-saving medications.
Here at RPh Innovations, we want nothing more than to help affected health centers recoup what has been lost and re-establish the access they deserve and need. During a recent webinar series for HCAN, we discussed some tips and tricks on navigating pharmacy designations and provided a checklist to assist Entities in the process, so that no steps were overlooked. Here are some of the important steps to keep in mind:
- Complete an analysis to determine which pharmacy to designate per each manufacturer. Don’t forget to consider your self-pay or charity programs!
- Consider if your health center will be submitting Claims Data to 340B ESP and setup the necessary resources to do so.
- Complete all designation forms and/or submissions. Make sure to have the pharmacy DEA and HIN (if applicable).
- Discuss your options with other resources such as, your TPAs or consultants. This will help you determine if a “lookback” to recapture missed claims is possible.
- Double check pricing when designations have been completed and stay on top of any further communications from the manufacturers.
Over the last several months, we have seen Covered Entities regain an average of 20% in 340B savings from their designations and lookbacks. But some entities did not stop there. Instead, these health centers sparked conversations about how to create more access for their patients, how to generate potential savings, and what avenues to explore to sustain their programs. This became a great opportunity for Entities to learn about referral capture and specialty pharmacies, as they would apply to 340B. It also became an opportunity to share ideas and lean on each other in the 340B Community.
All the changes circulating had entities at the forefront of their programs, changing the way they viewed their approach in sustaining 340B savings within their organizations.
RPh Innovations is often asked, “where is 340B headed?” To answer that question, unfortunately, there is no definite answer. 340B is always revamping, reshaping, and molding into what we need it to be to honor the intent of the program and help our communities. As 340B entities, pharmacies, and third-party stakeholders, we should instead focus our attention to answering the question, “what can we change?”
written by: Anita Miller, RPh Innovations