Since its creation in 1992, the 340B discount prescription drug program has continued to expand and provisions in the new health care reform law, as well as a “tax extenders” bill pending in Congress, will grow the 340B program’s reach further still. What does it mean for independent community pharmacies?
Is 340B expansion a threat as lax or ambiguous eligibility guidelines allegedly permit well-insured patients to purchase their medication outside of community pharmacies and at taxpayer-subsidized prices that should be reserved for the uninsured and truly indigent? Or are 340B programs a new opportunity for community pharmacies to contract with qualified entities to serve additional patients and to receive a reasonable dispensing fee? Or both?
To help independent community pharmacists navigate these waters, NCPA recently hosted a teleconference for 100+ local pharmacists with two leading experts. Paul Shank, the Consultant Coordinator for the U.S. Health Resources and Services Administration’s Pharmacy Services Support Center (PSSC), and David Schwed, President of Woodruff’s Drugs in Bridgeton, N.J., spent an hour sharing their views and answering questions. The discussion was part of NCPA’s Member Forum series – pharmacist-to-pharmacist discussions that allow NCPA members to learn first-hand about major topics like accreditation for Medicare’s Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) program, immunizations, new technology, etc.
Among the issues Messrs. Schwed and Shank covered on the 340B call:
- Contracting with a disproportionate share hospital (DSH), rural hospital, federal health center or other qualified 340B entity can and must be a win-win for the 340B program and the pharmacy before the pharmacy signs that contract.
- The “one pharmacy per site” rule has been changed, allowing covered entities to contract with more than one local pharmacy.
- There are 14 different types of 340B entities and that list is expanding.
- Some independent pharmacies may need outside administrative help, but beware of pharmacy benefit manager-type structures that seek to get between the 340B entity and the pharmacy and can be gamed by the middleman. Third-party contracts in this area must be carefully reviewed, ideally with the help of a health care attorney and/or a pharmacy services administration organization, or PSAO.
- 340B partnerships can be about more than the dispensing fee. Some pharmacies work with the physicians and others to provide comprehensive services and get involved with patient safety initiatives.
These experts also addressed other key 340B questions such as:
- A 340B entity in my area has contracted with another pharmacy in the area. What can I do?
- Do current pharmacy software programs support 340B transactions?
- When can someone with commercial health insurance also use the 340B program?
- How can my pharmacy receive technical advice from HRSA’s Pharmacy Services Support Center?
- Can pharmacists be reimbursed for medication therapy management (MTM) services under a 340B arrangement?
- Why have 340B programs migrated to a replenishment inventory model? Is a separate inventory model practical?
To hear a replay of the conference call and view the presentation, NCPA members can go to www.ncpanet.org, log into the Members Only section and click on the Member Forum link. Previous Member Forum discussions are available for download there as well. Or for more, contact NCPA’s Bill Popomaronis or Lisa Fowler. And, on the regulatory side, clarifying the 340B program’s eligibility requirements continues to be a priority for NCPA and something we’re working on with Congress and HRSA, the agency that oversees the program.