340 B FTE Request Template Slide Deck Purpose

340 B FTE Request Template Slide Deck

Purpose and Instructions Purpose This tool serves as a customizable template to support new 340 Brelated staff requests by the hiring manager (manager/director/VP) to present to the organization’s C-suite (approving body) Instructions • Aspects of the presentation should be tailored to your organization’s mission and values − Slides will note where organization-specific information is necessary • Best practice: obtain your annual 340 B purchases and calculate 340 B savings to fully optimize this presentation − For assistance with calculating 340 B savings, check whether your wholesaler provides a report comparing 340 B purchases to what the price would have been on a WAC or GPO account − Reference the Dashboard Best Practices Tool, available at https: //www. 340 bpvp. com/education/340 b-tools/ • This template contains core slides that are appropriate for all entity types and a separate appendix to select specific slides that pertain to your FTE request • The notes section below includes slide background and instructions © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 2

340 B Program Overview Intent “ To permit covered entities to stretch scarce Federal resources as far as possible, reaching more eligible patients and providing more comprehensive services. H. R. Rep. No. 102 -384(II), at 12 (1992) “ The 340 B Program gives health care providers who are responsible for larger proportions of vulnerable patients the ability to purchase medications at a reduced price © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 3

340 B Program Overview Savings Entities generate savings by purchasing 340 B drugs at a lower price than what they would have paid if not participating in 340 B (i. e. , GPO or wholesaler pricing) Example • Physician administers 340 B drug to an eligible outpatient − 340 B price: $70 − Non-340 B price: $100 − 340 B savings: $30 • Best practice: 340 B savings reinvested in entity services Non-340 B acquisition cost: $100 – 340 B acquisition cost: $70 $30 savings from 340 B − Examples: community benefit, charity care, drug access programs, free clinics, sliding fee scales © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 4

*Entity Name* 340 B Savings Physician-administered/clinic savings $___ savings Entity-owned retail pharmacy savings $___ savings Contract pharmacy impact $___ savings 340 B compliance maintenance costs $ –___ costs 340 B net financial impact $___ savings © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 5

Importance of 340 B Resources Program Compliance and Optimization • Lead 340 B self-audits − Readiness for HRSA and manufacturer audits • Provide relationship and oversight of third parties − 340 B vendors − Contract pharmacies • • • Optimize program value to the entity Lead 340 B oversight council Respond to manufacturer inquiries Provide ongoing staff education Communicate 340 B savings and how they are used © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 6

Importance of 340 B Resources Consequences of HRSA audit and noncompliance • • • Repayment to manufacturers Termination of covered entity from 340 B Program Termination of child sites from 340 B Program Termination of contract pharmacies from 340 B Program Increased scrutiny from state Medicaid programs © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 7

340 B Resources Benchmarking *Insert slide from “Appendix I – Benchmarking” based on our CE type* Include your annual outpatient drug expenses © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 8

340 B FTE Request with JD *Insert slide from “Appendix II – Job Descriptions” with entity-specific data pertaining to your request* Include primary focus of the position you are requesting Show the cost of the FTE is offset by affecting 340 B savings and minimizing compliance risk © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 9

Oversight Council *Insert slide from “Appendix III – Oversight Council” with entity-specific data pertaining to your request* Include this slide only if you’re planning on having this FTE lead or be part of your oversight council © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 10

Conclusion • Recap FTE request and purpose of role • Summarize benefit of position and risks without the role © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 11

340 B Resource Trends • According to a 2019 American Society of Health-System Pharmacists (ASHP) survey of multi-hospital pharmacy executives: − “ 340 B System Manager” was the third most common system-level pharmacy position − “ 340 B System Manager” was the second most common position reporting to the system-level Chief Pharmacy Officer − Respondents reported the position “ 340 B System Manager” to have the following number of direct reports: • 0 -3: 34 respondents (64%) • 4 -9: 13 respondents (25%) • 10 -15: 6 respondents (11%) © 2019 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 12

GPO Prohibition Hospital Benchmarks (DSH/PED/CAN) Outpatient drug expenses Average number of 340 B FTEs % with an oversight council % completing monthly audits % said had enough resources % said confident could pass an audit <$10 M (n=6) 1. 12 50% 17% 33% $10 M–$35 M 5. 17 100% 75% 67% 100% 4. 47 100% 80% 100% 6. 67 67% 33% 67% (n=4) $35 M–$75 M (n=5) >$75 M (n=3) © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 13

Rural Hospital Benchmarks (CAH, SCH, RRC) Outpatient drug expenses Average number of 340 B FTEs % with an oversight council % completing monthly audits % said had enough resources % said confident could pass an audit <$100 K (n=2) 0. 35 50% 0% 0% $100 K–$325 K 0. 58 50% 75% 25% 2. 35 50% 0% 50% 100% 8. 25 100% (n=4) $1 M–$1. 5 M (n=2) >$30 M* (n=3) © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 14

Community Health Center Benchmarks Outpatient drug expenses Average number of 340 B FTEs % with an oversight council % completing monthly audits % said had enough resources % said confident could pass an audit <$101 K (n=3) 0. 65 0% 33% 100% $101 K–$499 K 0. 60 40% 80% 60% 0. 89 25% 75% 1. 72 25% 57% 38% 88% (n=5) $500 K–$1 M (n=4) >$1 M (n=7) © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 15

Grantee Benchmarks Outpatient drug expenses Average number of 340 B FTEs % with an oversight council % completing monthly audits % said had enough resources % said confident could pass an audit <$101 K (n=7) 0. 65 0% 33% 100% $101 K–$499 K 0. 60 40% 80% 60% 0. 89 25% 75% 1. 72 25% 57% 38% 88% (n=7) $500 K–$1 M (n=2) >$1 M (n=3) © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 16

340 B Manager/Coordinator Job Duties 340 B Registration − Responsible for 340 B OPAIS accuracy as primary contact Policy and Procedure Development − Monitors newly passed legislation and guides program changes − Collaborates with 340 B Prime Vendor Program on best practices Audit Supervisor − Develops and executes regular auditing program − Evaluates necessary self-reporting and needed program changes Program Optimization − Reviews and negotiates new 340 B contracts − Assesses opportunities for cost savings (sub-WAC, sub-340 B) *Pull relevant duties from 340 B Manager and Coordinator JD Template Tool on 340 bpvp. com/education/340 b-tools* © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 17

340 B Analyst Job Duties Auditing − Participate in self- and external audits of 340 B Program − Evaluate patient eligibility and 340 B compliance Financial Analysis − Recognize 340 B financial impact Reporting − Develop reports to assist in tracking financial impact of 340 B to the entity − Monitor, report, and analyze contract pharmacy data Split-Billing − Supervise and audit 340 B split-billing software; coordinate purchasing and buyer compliance *Pull relevant duties from 340 B Analyst JD Template Tool on 340 bpvp. com/education/340 b-tools* © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 18

Salary Benchmarking Average Salary Range 340 B Program Manager 340 B Coordinator 340 B Analyst $93, 389 $64, 612 $54, 216 $40, 000–$175, 000 $30, 000–$150, 000 $25, 000–$80, 000 Pharmacist Average $140, 000 (n=5) $140, 000 (n=2) N/A Non-Pharmacist Average $76, 743 (n=14) $54, 560 (n=15) $54, 216 (n=10) © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 19

340 B Oversight Council Key Roles of 340 B Oversight Council • Responsible for operational and strategic decision making to ensure integrity of the program • Ensures that 340 B savings are used in accordance with program intent • Reviews self-audit results, ensure that discrepancies are corrected, and determine material breach of compliance process requiring selfdisclosure to HRSA • Improves understanding of the 340 B Program across the organization © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 20

Oversight Council Benefits Per the 2017 Prime Vendor Program member survey, organizations with 340 B oversight councils were: • 27% more likely to perform audits on a monthly basis, allowing them to more quickly make operational changes to support compliance • More likely to be confident in their ability to pass an audit © 2019 2018 Apexus. Reproduction without permission is prohibited CONFIDENTIAL. Do not distribute | 21