As we move into summer, the nation is cautiously reopening to varying degrees and we’re all finding our “new normal,” in a post-COVID-19 world, complete with face masks and social distancing. HRSA has released some new FAQs that will increase 340B savings for covered entities, HHS has released new funding to safety-net hospitals as part of the CARES Act, and we’ve got new exciting details about the upcoming 340B Coalition Virtual Summer conference. We wish you all a safe and healthy start to your summer.
New HRSA FAQs expand potential 340B eligibility
Earlier this month, HRSA and its contractor for the 340B Prime Vendor Program quietly updated several FAQs on its website and, without any fanfare, one of the new questions that was added could make a big difference to covered entities. The question reads:
“Q: Are hospital covered entities able to register offsite, outpatient facilities before being listed as reimbursable on their Medicare Cost Report?
A: In order to register for the 340B Program and be listed on the 340B Office of Pharmacy Affairs Information System (340B OPAIS), HRSA must first verify that the offsite, outpatient facility is listed as reimbursable on the hospital’s most recently filed Medicare Cost Report and has associated outpatient costs and charges as outlined in HRSA’s 1994 Outpatient Hospital Facilities Guidelines.
HRSA notes that for hospitals who are unable to register their outpatient facilities because they are not yet on the most recently filed Medicare Cost Report, the patients of the new site may still be 340B eligible to the extent that they are patients of the covered entity. These situations should be clearly documented in the covered entity’s policies and procedures. In addition, a covered entity is responsible for demonstrating compliance with all 340B Program requirements and ensuring that auditable records are maintained for each patient dispensed a 340B drug.”
What does this mean for covered entities? Essentially, until now, covered entities were required to file their offsite, outpatient facilities on their Medicare Cost Report (MCR) and then wait – sometimes up to 22 months – before that site was registered with CMS before the site would be 340B eligible and they could begin collecting savings from the 340B program.
According to this new Q&A item, that is still the case, with one small but significant change. “For hospitals who are unable to register their outpatient facilities because they are not yet on the most recently filed Medicare Cost Report, the patients of the new site may still be 340B eligible to the extent that they are patients of the covered entity.” Meaning that even though it may still be more than a year before the offsite, outpatient facility is officially registered as a 340B site, patients treated at the offsite location may still be 340B eligible. The result is that, if the covered entity can provide adequate documentation that those patients are patients of the covered entity, they can be prescribed drugs eligible to be purchased at the discounted 340B rate, thereby allowing the covered entity to reap the benefits of 340B savings far sooner than previously possible. For rural hospitals and small, offsite clinics treating indigent patients, collecting those saving earlier can mean the difference between keeping doors open to serve vulnerable populations or not.
What should you do next? If you have an offsite, outpatient facility that you believe meets or will meet these criteria in the coming months, please contact your Sentry account management team so we can assist you with mapping the location and validating your data feeds.
HHS directs $25B in CARES funding to Medicaid providers and safety net hospitals
On June 9, HHS announced that, as part of the CARES Act, it will deliver $25 billion to providers and hospitals that serve the nation’s most vulnerable patients, or those with Medicaid and Children’s Health Insurance Program coverage. “Of that, $15 billion will go to providers that primarily serve Medicaid and CHIP patients while the other $10 billion is reserved for safety net hospitals that usually operate on razor-thin margins,” Healthcare Dive reports. “A total of 758 safety net hospitals will receive direct deposits, and the administration noted that many of these facilities are operating in the red with an average profit margin of -7%.”
“Our goal for all these distributions has been to get the money to the providers who need it most as soon as possible,” Eric Hargan, HHS deputy secretary, said during a call with reporters.
“The funds are intended to help hundreds of thousands Medicaid providers that did not receive funding through the general distribution that went out to providers in April and May,” explains MedCity News. “For example, community health centers, which provide healthcare services to low-income patients, and speech therapists and physical therapists that primarily serve children with disabilities were not included in the initial distributions of funding.”
“Healthcare providers who focus on treating the most vulnerable Americans, including low-income and minority patients, are absolutely essential to our fight against COVID-19,” HHS Secretary Alex Azar said in a press release.
340B Coalition Virtual Summer conference is right around the corner
- Reduced registration fees; extending early bird rate
- An agenda spread out into easy-to-consume time slots over five days spanning two work weeks (July 20 – 29)
- 50 sessions plus three pre-conference workshops, all covering not only policy changes related to COVID-19 but other developments that will continue to affect the day-to-day operations of your 340B programs long after the pandemic has ended
- Most sessions recorded, so if you can’t attend live or want to watch sessions that occur at the same time, they will be available on demand for up to three months
- Continuing education credits for both live and on-demand sessions
- Multiple interactive opportunities to network with 340B professionals and exhibitors via chat, video conference, forums, and social feeds.
More information about the virtual experience can be found on the conference FAQ page. Sentry looks forward to connecting with you during the event; we’ve even got a virtual presentation or two of our own up our sleeves – stay tuned for more!
Sentry in the spotlight
Sentry’s own Head of Industry Relations, Lisa Scholz, PharmD, FACHE, recently delivered a short webinar for 340B Health as part of their virtual series, “340B Updates from the Field.” Scholz’s presentation, “340B of the future: adaptation and the human spirit,” discussed the major changes that the healthcare industry – and the 340B program – have undergone before, during, and in the aftermath of the COVID-19 pandemic, and the power of adapting to watershed moments in history.
Until we meet again – stay healthy!