340B Insight 340B Health

340B compliance is a critical requirement for hospitals participating in the program, and one of the ways 340B hospitals maintain compliance is through conducting internal audits. For this episode, we speak with Tristan Greer, 340B program business manager at Catholic Health in Buffalo, N.Y. Tristan has significant experience conducting 340B internal audits at the health system, and she shares several best practices for a successful internal audit. Before the interview, we provide a news update on how drug manufacturers are pursuing legislative changes to 340B and some of the responses to that proposal. 

The Benefits of Internal Audits 
Internal audits help 340B covered entities stay in compliance. Tristan outlines the internal audit process her health system uses and how this supports the overall compliance effort. She also explains how the internal audit process has changed over time. 

What HRSA Expects from Internal Audits
Tristan discusses what HRSA expects hospitals to share about their 340B internal audits. 

Staying Organized During Internal Audits 
Tristan shares her approach to accomplishing a successful internal audit, including which materials her hospital gathers for the process. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you’d like us to cover in this podcast, email us at podcast@340bhealth.org.

Resources 

340B Health Statement on PhRMA Proposal to Reduce Safety-Net Hospital Participation in 340B
Rep. Doris Matsui Statement on Proposal to Change 340B Program 

PhRMA Unveils More Details About Proposed 340B Hospital Eligibility Cuts 

340B Coalition Winter Conference  

State policymakers have increased the attention they are paying to 340B. In this episode, we hear from 340B state advocacy expert Abby Reale. Abby is director of government and external affairs with Mountain Health Network in West Virginia. The state has been a leader in protecting 340B, and she shares how her health system worked with other hospitals and provider organizations to advocate for the first 340B non-discrimination law in the nation. Prior to the interview, we provide a news update about a drug company that is imposing the pharmaceutical industry’s most restrictive limits on 340B pricing.  

Why You Need to Pay Attention to State Health Policy  
Abby discusses the power states have to regulate health care. 

Advocating for a 340B Non-Discrimination Law 
Abby details the steps her hospital and other provider organizations took to help state legislators understand the need to stop payer and pharmacy benefit manager (PBM) payment discrimination against 340B providers. She also explains the work advocates sometimes need to do to ensure laws are enforced. 

Joining 340B State Advocacy Efforts 
Abby shares how 340B professionals can join advocacy efforts in their states and how advocacy differs between the state and federal levels. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at podcast@340bhealth.org.

Resources 


Statement on New Johnson & Johnson Restrictions on 340B Access 
Contract Pharmacy Dispute Resources for 340B Health Members

340B Coalition Winter Conference 

Health information technology (IT) is intertwined with 340B operations and compliance. So how can hospitals and health systems manage IT while keeping 340B in mind? To find out, we hear from Robert Owens, director of pharmacy enterprise shared services at Atrium Health. Bob is a pharmacy health IT expert, and he shares how the technology intersects with 340B. He also shares insights to ensure strong 340B operations and compliance when undergoing an electronic health records (EHR) system conversion. Before the interview, we provide an update on two more drug companies restricting 340B discounts.  

IT's Intersection With 340B Operations
Bob discusses the different types of IT systems providing data that are important for closely monitoring your 340B program, including electronic health records, automated dispensing cabinets, and IV workflow software. He emphasizes the importance of the 340B team members becoming experts on 340B data. 

EHR Conversions
Bob explains how EHR system conversions affect 340B operations and compliance. He walks through the steps his team took before and during one of its conversions and points out the potential pitfalls to avoid.  

Strategies for Managing NDCs 
An EHR conversion means 340B professionals need to be aware of potential NDC challenges that go along with it. Bob shares some questions 340B professionals should ask about charging and administration practices when planning for a change in EHR systems. 
Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at podcast@340bhealth.org.

Resources 


List of Drugmaker 340B Restrictions Grows in Wake of Court Decision 
340B Insight Episode 67: Maureen Testoni’s Outlook for 340B in 2023

340B Coalition 2023 Winter Conference 

Several 340B developments have occurred in the first weeks of 2023, with many more expected to come this year. In this episode, we speak with 340B Health President and CEO Maureen Testoni about her outlook for 340B. Our discussion includes her analysis of the latest in the 340B contract pharmacy dispute, the 340B advocacy landscape at the federal and state levels, and Medicare issues affecting 340B.

*Editor’s note: We spoke with Maureen prior to Bayer and EMD Serono announcing they will restrict 340B discounts. When these restrictions start in March, at least 21 companies will be limiting 340B discounts, with 14 of these companies conditioning 340B pricing on providers sharing contract pharmacy claims data.*

We often receive listener questions about 340B issues and developments that affect professionals in the 340B world. In this episode, we open the listener virtual mailbag and answer some of your questions with help from our 340B Health staff experts. Some of the questions we tackle include queries about mitigating 340B contract pharmacy restrictions, understanding 340B patient definition, analyzing current 340B hospital audit trends, and examining Medicare Advantage payment rates for 340B drugs.

Providing care beyond hospital walls is a growing trend for 340B hospitals. One service that health systems provide outside of the hospital setting is home infusion care. On our first episode of 2023, we are joined by David Klinger and Seth Gazes from Geisinger Health to hear how 340B hospitals can establish home infusion care and the 340B considerations they should keep in mind. Prior to the interview, we provide an update on the 19th drug company to restrict 340B discounts for drugs dispensed at community and specialty contract pharmacies. We also recap drug manufacturer 340B overcharge notices in 2022.