Top 3 340B Priorities

340B industry leaders cite top three priorities; understaffing a key concern

Sentry Data Systems recently hired Envision Health, a Detroit-based, clinically informed healthcare marketing and PR consulting firm, to conduct in-depth research interviews with hospital 340B program managers and leading independent 340B consulting firms to better understand their top 340B priorities. Following are highlights from the interviews:

#1: Compliance

Not surprisingly, compliance was the top priority. Said one user, “This keeps me up at night. The more I learn, the more I become concerned about missing something.” Another commented,We often feel lost and afraid when it comes to the complexity of the 340B program. We desperately need [our vendors’] help, and are personally and professionally affected by the risks inherent in the 340B program.”

An independent 340B consultant who works with a variety of 340B vendors described Sentry as one of his “favorite solutions.” Whenever a client of his has an audit, he said, “I hope that it is a Sentry client.” Overall, 340B program managers consistently cited that Sentry “has a more robust solution” and provides them with peace of mind. These clients told us they have “a high degree of confidence in compliance because Sentry stays on top of legislation and regulation.” With significant legislative changes looming, this was cited as a major source of relief.

#2: Financial stability through needed program benefits

Compliance was closely followed by financial stability through needed program benefits. All research participants described 340B benefits as critical to accomplish their mission of caring for the underserved in their communities. One hospital participant referenced the importance of using 340B savings to help address unmet healthcare needs: “When the ACA started, people thought there would be less of a need for charity care, but we’re finding that more people are now under-insured.” Yet another East Coast health system cited the program’s impact in terms of providing greater access to care within their community: “340B is an incredibly high priority. Without 340B, we’d have to shut down half our sites.”

According to one major health system representative, “340B is a high priority for the upper management at our health system. The 340B program has become a major form of life support for the communities where we have facilities. Our overall charity care increased by 14.7% as a direct result of 340B savings.” Another health system representative said, “340B savings have become incredibly important to our organization and we can’t rely upon some ‘Johnny come lately’ vendor. We need to work with Sentry due to the complexity of our system, the size of our contract pharmacy network, and so on.”

#3: Program optimization

Program optimization rounded out the top three concerns. One 340B program manager said, “Help me avoid unnecessary costs. In an ideal world, if you need to order a drug that’s eligible for GPO and there’s no difference in price, then you’ll purchase it on WAC, so you’ll preserve your GPO accumulations. Our buyers do this today; however, it is a very manual-intensive process.”

Another participant noted, “340B is constantly changing, and Sentry not only helps us to stay on top of the program’s increasing complexity; they help us identify opportunities to optimize program performance in ways we couldn’t do on our own.” Several participants cited Sentry’s eRx Eligibility Check, a data extract option that uses hospitals’ existing e-prescription data to tie prescriptions to the service location. Said one, “I see the value – because knowing when my patient status changes (e.g., from inpatient to outpatient) allows me to bill more accurately to optimize program savings while enhancing compliance.”

Understaffing a key concern

Given the increasing complexity of 340B, we weren’t surprised to hear that maintaining compliance keeps 340B managers up at night. However, our most compelling finding was that virtually all hospital 340B managers felt they were short-staffed.

This finding is in line with what the industry is reporting overall. In a presentation from Apexus, delivered at the ASHP December 2017 Midyear Meeting, a survey of 79 individuals from various hospitals and health centers found that 53% of respondents whose organizations had a 340B oversight council, and 38% of respondents whose organizations did not, felt that they did not have enough resources to successfully administer the 340B program. The survey also found that those organizations with an oversight council had larger full-time employee (FTE) programs, engaged in more self-auditing, and had more confidence in their ability to pass an audit, and that FTE resources increase with increased size and complexity of an organization’s 340B program. Additionally, the organization 340B Health conducted a survey of 156 hospital employees, which found that of the 43 hospitals with a completed audit, 47% found that the audit resulted in increased resources, and that 12% of hospitals that were undergoing an audit at the time of the survey reported adding resources. “It is possible that audited facilities may not have had appropriate resources prior to audit,” the 340B Health report concludes. “Non-audited hospitals may want to evaluate their resources, since most audited hospitals found they were under resourced for audits.”

This lack of sufficient resources, combined with the pressure to maximize program benefits while streamlining operations, creates a perfect storm of opportunity, risk and compliance pressure. 340B managers’ concerns about understaffing may also explain why they responded so positively to Sentry’s recently introduced Senturion services team. They saw value in experts who could support their 340B program by “maximizing savings/ROI,” “identifying opportunities to expand 340B program to other sites,” and “advising critical access hospitals in rural areas.”

In summary, both 340B program managers and industry consultants saw opportunities to use Sentry’s in-house pharmacy expertise and analytics solutions to “capture savings” and “identify missing healthcare procedure codes” to help maximize program benefits and further maintain compliance—without burdening hospitals’ limited 340B resources.