dana rph director pharmacy rapid city regional...
TRANSCRIPT
Dana Darger, RPhDirector of Pharmacy
Rapid City Regional Hospital
Statement of Conflicts of Interest Dana Darger has no actual or potential conflict of interest in relation to this presentation
Today’s Agenda Composition of a Hospital 340B Compliance Team Why have a compliance program Hospital 340B Self‐audit
Who Is Regional Health• Rapid City Regional Hospital
‐417 Bed Disproportionate Share Hospital• Spearfish Regional Hospital
‐40 Bed Sole Community Hospital• Sturgis Regional Hospital
‐25 Bed Critical Access Hospital• Custer Regional Hospital
‐16 Bed Critical Access Hospital• Lead‐Deadwood Regional Hospital
‐18 Bed Critical Access Hospital
Why Is a Compliance Program Necessary HRSA
“340B Drug Pricing Program covered entities must ensure program integrity and maintain accurate records documenting compliance with all 340B Program requirements.”
“The 340B Program offers eligible safety net health care providers access to low‐cost medications, which allows them to expand the type and volume of care they provide to the most vulnerable patient populations. HRSA places the highest priority on the integrity of the 340B Program and continually works to strengthen the oversight of this program.”
340B Compliance Committee VP Compliance Legal Services 340B Specialist Assistant Director Outpatient Pharmacy Services Pharmacy Business Support Supervisor Pharmacy Staff Accountant Director of Pharmacy
340B Team
Policies and Procedures Definitions Operational
Audits Stewardship
Wholesaler Vendor Split Billing Contract Pharmacy Child Sites
Medicare Cost Reports Registration and Recertification Contracts or MOUs with Government Entity Contract Pharmacy Contracts
Compliance Program Key Elements
Patient definition Covered drug definition Duplicate Discount
Carve In or Carve Out Medicaid – your state Medicaid – other states
Exclusions GPO Orphan Drug
Contract Pharmacy Patient eligibility Contracting Duplicate discounts
What Are You Going to Audit?
Policy and Procedures When were they last reviewed or updated – ours is yearly, at a minimum
Are there gaps in what you do and the policies that you have Do you follow your policies
Patients Can you clearly demonstrate that only eligible patients are qualifying? Medical record Eligible provider
Self‐Audits
Split Billing Self‐Audit Frequency of Self‐Audits
DSH – Quarterly Randomly select 30 claims from each wholesaler account
CAH/Sole Community – 1 facility per quarter All transactions
Purchasing Can you track 340B purchases to eligible patients? Can you track WAC purchases to non‐eligible outpatients? Can you track GPO purchases to only inpatients
Contract Pharmacy Self‐Audits DSH quarterly contract pharmacy audits
Randomly select 30 claims from each contract pharmacy
CAH/Sole Community 1 facility per quarter – 30 randomly selected claims from each contract pharmacy
Eligible patients Medicaid exclusions? Billing, shipping and receiving
Independent Audit 3rd Party – outside vendor audit
Yearly
• Entity eligibility issues• Report to OPA• Stop purchasing
• Patient or covered drug eligibility issues• Repay amounts to manufacturers or determine the manufacturer’s preference
Reporting Self‐Audit Discoveries
$‐
$100,000.00
$200,000.00
$300,000.00
$400,000.00
$500,000.00
$600,000.00
$700,000.00
12/13 1/14 2/14 3/14 4/14 5/14 6/14 7/14 8/14 9/14 10/14 11/14 12/14
EOM Running Balance
EOM Running Balance
2 per. Mov. Avg. (EOM Running Balance)
Hmmmmmmmmm
Hmmmmmmmmmm
$0.00
$10,000.00
$20,000.00
$30,000.00
$40,000.00
$50,000.00
$60,000.00
$70,000.00
12/13
1/14
2/14
3/14
4/14
5/14
6/14
7/14
8/14
9/14
10/14
11/14
12/14
EOM Running Balance
EOM Balance 2 per. Mov. Avg. (EOM Balance)
Additional Questions?
Dana Darger, RPhDirector of Pharmacy353 Fairmont BlvdRapid City, SD
Phone: 605‐755‐[email protected]