Earlier today, KHA submitted comments to the Cabinet for Health and Family Services (CHFS) Department of Medicaid Services (DMS) on the proposed changes to the 340B Policy and Procedures Manual.

KHA's comments outline how the proposed changes would impose additional and substantial burdens upon Kentucky hospitals without any corresponding benefit. Kentucky hospitals are in full support of assuring program integrity and expanded access to lower cost drugs to Covered Entities and their patients; however, the proposed changes, as written, should be delayed until clarified and improved

A full copy of the comment letter is available to members on the Policy page on the Advocacy section of KHA's website, www.kyha.com.

The Kentucky Department for Medicaid Services (DMS) is requesting feedback on the proposed DMS 340B Policy and Procedures Manual. The Department is extending the deadline for all feedback to October 3. The effective date of the proposed policy will be set to January 1, 2020.

Please email all feedback to jade.range@ky.gov.

Safety net hospitals struggle to stretch scarce resources to provide crucial services to their patients while meeting their bottom line. It does not have to be this way. When managed compliantly, the 340B program does what it was intended to do: secure the financial future of safety net organizations who serve the nation’s vulnerable population.

The 340B program can have a significantly positive impact for hospitals, their patients and their communities if hospitals know how to administer and manage the program effectively.

KHA will host a 340B Compliance Workshop on June 27 in Louisville where subject matter experts will present insights for safety net hospitals to tap into the benefits of the 340B program, including increasing financial support that enables hospitals to provide better care, improve patient outcomes and help the indigent/uninsured gain access to the discounted medications they need.

View the program flyer...

Does your invoice analysis tool check wholesaler charges against the 340B drug pricing program?

Many hospitals have tools to analyze the charges their GPOs invoice to identify discrepancies and overcharges. KHA Solutions Group's Affinity Partner SUNRx provides an Invoice Analysis tool that is unique. No other tool in the industry has the ability to check wholesaler charges against the 340B drug pricing program. This is because other GPO analysis tools don't have access to 340B pricing.

The average savings using the SUNRx Invoice Analysis tool is between 2-5%.

If you are looking to reduce drug spend costs, contact Pam Kirchem at KHA Solutions Group (pkirchem@kyha.com) to learn how SUNRx can help.

The Health Resources and Services Administration's (HRSA's) Office of Pharmacy Affairs will host a webinar on August 8 to assist covered entities with the recertification process for the 340B drug savings program.

Hospitals can join the webinar, which takes place from 1:00 p.m. to 2:00 p.m. (ET), by visiting https://hrsaseminar.adobeconnect.com/dpp_340b_pepi/.

The conference number is 800-967-7154 and participant passcode is 847321.

All 340B hospitals are required to recertify with HRSA to ensure they continue to meet the 340B hospital eligibility requirements. The hospital recertification process runs from August 15 to September 12. HRSA recently stated it may request additional information from covered entities during the registration process. These additional program integrity requests are specific to hospital eligibility documentation and contract pharmacy agreements of all covered entities...

On May 16, the Department of Health and Human Services (HHS) released a request for information on ways to lower drug prices and reduce out-of-pocket costs for consumers.

While the AHA appreciates the Administration's focus on the issue of unsustainable drug prices, which threaten patient access to care, the focus on the 340B program as part of a plan to lower drug prices is misplaced. A number of the questions raised by HHS suggest that the 340B program might contribute to higher drug prices. However, it is drug manufacturers,...

The 340B Prescription Card Program from SUNRx helps 340B entities pass along savings to patients. Eligible hospitals and clinics struggle to stretch their scarce resources to provide the crucial services their patients need while maintaining financial security. And while many patients they serve can’t afford to pay for high priced medications, it doesn’t have to be this way — a 340B program administered by SUNRx can help.

SUNRx’s 340B prescription card program provides a conduit for covered entities to pass along 340B savings to their patients. Because SUNRx is a wholly owned subsidiary of pharmacy benefit manager (PBM), MedImpact Heathcare Systems, this 340B prescription card program is unique from others. SUNRx confirms 340B patient eligibility and applies its “lower of” cost calculation to find the lowest price available for the patient. This process is accomplished in real time when your patient presents...

Eligible hospitals struggle to stretch their scarce resources to provide the crucial services their patients need while maintaining financial security. And while many patients they serve can’t afford to pay for high priced medications, it doesn’t have to be this way — a 340B program administered by SUNRx can help.

SUNRx’s 340B prescription discount card program provides a conduit for covered entities to pass along 340B savings to their patients. Because SUNRx is a wholly owned subsidiary of pharmacy benefit manager (PBM), MedImpact Heathcare Systems, this 340B prescription discount card program is unique from others. SUNRx confirms 340B patient eligibility and applies its “lower of” cost calculation to find the lowest price available for the patient. This process is accomplished in real time when your patient presents the 340B prescription discount card along with their prescription to the contract pharmacy....

KHA will host a 340B Compliance Workshop on June 21 in Louisville. The program offers 1.5 ACHE Face-to-Face credits.

Safety net hospitals struggle to stretch scarce resources to provide crucial services to their pa tients. The 340B program is essential in ensuring that hospitals in Kentucky and nationwide are able to continue to provide pharmacy care to its most vulnerable patients.

The subject matter experts at this interactive workshop will present valuable insights on how safety net hospitals can effectively navigate the 340B program so they can improve patient outcomes and help low-income and rural patients access essential pharmacy services.

View the brochure for program details. Online registration...

KHA Solutions Group Affinity Partner SUNRx provides comprehensive, auditable technology solutions and high-touch customer service with a hands-on approach to program implementation, contract pharmacy setup and ongoing program management. They offer:

User-Friendly Covered Entity & Contract Pharmacy Interface

Dashboard reporting, claim trends, utilization by pharmacy Cloud-based virtual inventory management solution Extensive Network of More Than 22,000 Contracted 340B Pharmacies

National and regional chains Independent pharmacies In-house hospital pharmacies Customer Service

Seamless implementation High-touch program management Dedicated account executive to each covered entity Dedicated account manager to each contract pharmacy For more information on how SUNRx can help your facility, contact Pam Kirchem...

Safety Net Hospitals struggle to stretch scarce resources to provide crucial services to their patients while meeting their bottom line. It doesn’t have to be this way. When managed compliantly, the 340B program does what it was intended to do: secure the financial future of safety net organizations who serve the nation’s vulnerable population. The 340B program can have a significantly positive impact for hospitals, their patients, and their communities if hospitals know how to administer and manage the program effectively.

By utilizing KHA Solution Group's Affinity Partner SUNRx as their 340B Administrator, safety net hospitals have the ability to tap into the benefits the 340B program can provide:

Increasing financial support that enables hospitals to provide better care

Improving patient outcomes

Helping the indigent/uninsured gain access to the discounted medications they need.

SUNRx’s uninsured discount prescription card program provides a conduit for safety...

Stay one step ahead by registering for a free, one-hour webinar to educate hospitals on how the recent Centers for Medicare and Medicaid Services (CMS) payment policy changes (finalized November 1, 2017) impact hospital 340B Pharmacy Programs.

The American Hospital Association’s Aimee Kuhlman and Molly Collins will speak for 10-15 minutes on what the AHA is doing to represent hospitals’ 340B interests at the federal level. The rest of the webinar will be on the impact of the CMS changes in 340B Pharmacy and the actions a hospital can take.

Brought to you by the Kentucky Hospital Association in conjunction with SunRx, a compliance-focused 340B Drug Discount Program Administrator



Title: Trends and Drivers in 340B

Who should attend: Directors of Pharmacy, Pharmacy managers, CFOs or others responsible for profit/loss of hospital 340B programs

Registration: https://sunrx.webex.com/sunrx/onstage/g.php?MTID=e897bea4765d949bcd93825c0c1a2bd87

...

Yesterday, the American Hospital Association (AHA), the Association of American Medical Colleges (AAMC) and America’s Essential Hospitals filed a lawsuit against the U.S. Department of Health and Human Services (HHS) in the U.S. District Court for the District of Columbia to prevent significant Medicare payment cuts for hospitals that participate in the 340B Drug Pricing Program. The three hospital associations are joined in the suit by hospital plaintiffs: Eastern Maine Healthcare Systems, in Brewer, Maine; Henry Ford Health System, in Detroit; and Park Ridge Health, in Hendersonville, North Carolina, part of Adventist Health System.

For 25 years, the 340B program has enabled hospitals and other organizations that care for many low-income and uninsured patients to purchase certain outpatient drugs from pharmaceutical manufacturers at discounted prices. The program allows participating hospitals to use the savings from the discounts to provide an expanded range of comprehensive health...

Thanks to Kentucky Congressmen Hal Rogers, James Comer and John Yarmuth for signing a Dear Colleague letter urging the Centers for Medicare and Medicaid Services (CMS) to abandon its proposal to reduce Medicare Part B payment for drugs acquired through the 340B Drug Pricing Program. "Given the important role that the 340B program plays in our communities, we strongly urge CMS to abandon this proposal and redirect its efforts toward actions to address the cost of drugs via other policies that would not harm our constituents," the representatives wrote. 

CMS has proposed to pay for separately payable, non pass-through drugs purchased through the 340B program at the average sales price (ASP) minus 22.5%, rather than the current rate of ASP plus 6%. Two hundred twenty-eight members of the House of Representatives signed the letter to CMS. Eighty-five Kentucky hospitals qualify to receive 340B discounted outpatient drugs. Please join KHA in thanking Congressmen Rogers, Comer and Yarmuth.

For further...

On September 8, KHA submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Medicare hospital outpatient prospective payment system (OPPS) proposed rule for calendar year (CY) 2018. The Association has significant concerns with this proposal's reductions in payment for 340B hospitals as well as changes to remove total knee replacement from the inpatient only list, which is unsafe and will negatively impact hospitals participating in the CMS Comprehensive Care for Joint Replacement (CJR) and the Bundled Payment for Care Improvements (BPCI) programs.

A copy of KHA's comments are available on the Policy page (members only) of www.kyha.com.

If you have any questions, please contact Nancy Galvagni at KHA (ngalvagni@kyha.com).

The Centers for Medicare and Medicaid Services (CMS) is proposing to cut payments for most “separately payable Part B drugs” purchased under the 340B program and dispensed to Medicare hospital outpatients in its Medicare Outpatient Prospective Payment System (OPPS) calendar year (CY) 2018 proposed rule. “Separately payable Part B drugs” generally refer to those that have per-day costs about the packaging threshold, pass through drugs and certain antiemetics. CMS proposes payment at Average Sales Price (ASP) minus 22.5%, rather than ASP plus 6% (the current payment rate), for a nearly 30% cut.

Yesterday, KHA sent the chief financial officer of each 340B hospital paid under the OPPS a brief survey regarding the impact of this payment cut. KHA will summarize this data in support of its comments to CMS (due September 11)  opposing these cuts. 

CEOs, please encourage your CFO to respond to the survey by Wednesday, September 6.

If you have any questions, please contact Nancy Galvagni at KHA...

SUNRx is hosting a free webinar on 340B Audit Best Practices on Thursday, July 20 at 12:00 p.m. (ET). These webinars address specific topics of interest in 340B, and are part of the SUNRx Webinar Series available exclusively through KHA Solutions Group and other SUNRx partners.

Speaker Aaron Lott has extensive 340B audit experience and will be sharing current trends and drivers with regard to 340B audits that will help you position your hospital for optimal results. He is executive director of pharmacy services for Health Enterprises (HE). Lott specializes in services including pharmacy benefit management (PBM) and specialty pharmacy, 340B program implementation, auditing and education as well as implementation of provider-owned retail pharmacies and centralizing pharmacy services. 

This informative webinar event will discuss current trends and drivers in the world of 340B audits.

To register, visit https://sunrx.webex.com/sunrx/onstage/g.php?MTID=e34f739889625b5f8eaf4e07a3f2df0e6....

KHA Solutions Group Affinity Partner SUNRx offers the easiest and most effective way for rural health providers to take advantage of the 340B opportunity. SUNRx helps hospitals and health centers:

Generate Revenue. Capture revenue from patients with third-party coverage, and generate $40 or more from each qualifying claim. Reduce costs. Reduce the cost of medications for eligible patients by half. Launch contract pharmacy networks. Hospitals do not need a 340B inventory, additional staff or an outpatient pharmacy. SunRx can build a seamless network of retail pharmacies to dispense 340B discount drugs. Improve patient care. Help patients save money on medications so they fill their prescriptions, go to the emergency room less often and have...

On Tuesday, April 11, KHA Solutions Group Affinity Partner SunRX will host a free webinar on 340B Trends and Drivers. SUNRx is excited to provide eligible entities with access to this 340B Industry Update. This exclusive webinar will provide the latest updates in 340B including the impact of the Trump Administration.

Speaker details and login information are available at http://www.new-kyha.com/Portals/5/EventBrochures/SunRxWebinar.pdf.

If you have any questions about the webinar or about how SunRx can help with your 340B program, please contact Darrell Trent at KHA Solutions Group (dtrent@kyha.com).

On January 30, the Office of Management and Budget (OMB) officially withdrew the 340B “mega-guidance” released in August 2015, which would have changed which patients, drugs and providers qualify for the 340B discounts on prescriptions medicines.

The official regulatory notice can be found at https://www.reginfo.gov/public/do/eoDetails?rrid=126712.

Last week, the Medicare Payment Advisory Commission (MedPAC) approved a multi-layered recommendation that would grant hospitals a full payment update for 2017, as well as cutting payments for 340B drugs and redirecting some of the savings into uncompensted care funds that the Commission stated would benefit more hospitals under a new Medicare-based calculation than the current one based on Medicaid days. Three Commissioners opposed the recommendation.

Commission Chairman Francis Crosson noted hospitals would gain $3 billion in payments, while Medicare beneficiaries would gain some out-of-pocket savings on drug costs directly and others could benefit later if Medigap insurers pass savings along by lowering premiums. Opponents stated the policy recommendation could hurt some providers and strayed beyond MedPAC's competency in addressing the 340B program.

What You Need to Know

MedPAC voted to give hospitals a full 2017 Medicare payment update currently projected at 1.75 percentage points....

Reminder for all rural hospitals participating in the 340B Drug Pricing Program: The recertification period began August 5 and ends September 9. Participating hospitals have until September 9 to ensure program compliance and recertify in the 340B database maintained by the Office of Pharmacy Affairs. Each participating hospital or covered entity should have already received an email with the username and password necessary to complete recertification. An informational webinar and user guide on recertification are available for more information.

If questions arise, please direct them to Apexus, the 340B Prime Vendor Program (888-340-2787 or via email at ApexusAnswers@340bpvp.com)....

Eligibility in the 340B Drug Pricing program is reviewed annually by the Office of Pharmacy Affairs (OPA) and Covered Entities are required to recertify as a part of this process. Hospitals and safety net providers are currently up for recertification, and they must complete the process by September 10.

OPA recently sent email notifications about the recertification process to the Primary Contact and Authorizing Official for each Covered Entity. If your facility participates in 340B, please look for the email and begin the recertification process.

If you need assistance with the recertification process, visit the OPA web page on recertification, which includes key information about the process and a step-by-step guide to recertification.

The Health Resources and Services Administration (HRSA) has just released an interpretive rule explaining its position with respect to inclusion/exclusion of orphan drugs in the 340B program. This follows comments last week from HRSA in the wake of a court ruling that called the Agency's authority into question with respect to orphan drugs. The rule is available at http://www.ofr.gov/(S(ngyx2dlwh3mfa5sankgk5q04))/OFRUpload/OFRData/2014-17409_PI.pdf.

According to the summary, "The interpretive rule states that section 340B(e) of the PHSA excludes drugs with an orphan designation only when those drugs are transferred, prescribed, sold, or otherwise used for the rare condition or disease for which the drug was designated under section 526 of the Federal Food, Drug, and Cosmetic Act (FD&C Act)."

Another, more comprehensive 340B proposed rule has been under Office...

A federal court late Friday ruled in favor of the Pharmaceutical Research and Manufacturers of America (PhRMA) and against the Department of Health and Human Services (HHS) in a lawsuit seeking to exclude all drugs with an "orphan" designation from the 340B Drug Pricing Program expanded to rural and cancer hospitals under the Affordable Care Act. As a result of the ruling in the U.S. District Court for the District of Columbia, HHS's final rule is no longer in effect. The rule, which was issued in 2013, allowed certain 340B hospitals (critical access, sole community providers, rural referral centers and freestanding cancer hospitals) to purchase orphan drugs through the 340B program if they did not use the drugs for the treatment of conditions for which the orphan drug designation was given. AHA filed a friend-of the-court brief in December supporting HHS.

AHA and KHA will provide 340B hospitals more information on the court decision and its impact on hospitals. 

...

KHA Solutions Group, the Safety Net Hospitals for Pharmaceutical Access (SNHPA) and the Kentucky Chapter of the Healthcare Financial Management Association (HFMA) invite you to a complimentary forum covering critical issues relating to the federal 340B drug discount program. The program will be held on Friday, May 16, from 8:30 a.m. until 3:00 p.m. (ET) at the University of Kentucky College of Medicine in Lexington.

This event, which is exclusively for Kentucky 340B hospitals and health systems, will provide a closer look at the ongoing debate in Congress about hospitals’ use of the 340B program. As you know, the program faces growing criticism from powerful interest groups and influential lawmakers.

The forum will address these issues as well as cover operational and compliance aspects of 340B. In addition to an in-depth 340B briefing, attendees will hear about the latest developments in Washington that affect the Kentucky hospital community.

SPECIAL GUEST: Kentucky's Sixth District...