Enhancing 340B Compliance: A Deep Dive into FQHC 340B Compliance’s Monthly Coordinator Service

Enhancing 340B Compliance: A Deep Dive into FQHC 340B Compliance’s Monthly Coordinator Service

Federally Qualified Health Centers, or FQHCs, provide affordable and accessible healthcare to underserved communities. Ensuring compliance with the 340B Program is vital for FQHCs to maximize their impact and stretch federal funds efficiently. One critical service that sets FQHC 340B Compliance apart is its Monthly Coordinator Service. Tailored to address health centers' evolving needs, we strive to expand support for FQHC’s beyond the standard annual external audit check-up, to ensure health centers are able to maintain 340B compliance throughout the year. Various services within this program aid in maintaining robust 340B compliance for health centers, including internal audits, financial analysis and review, e-prescription review, 340B ESP designations and uploads, and 340B Program optimization.

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What Is Included in Our Monthly Coordinator Service?

The cornerstone of the Monthly Coordinator Service is monthly internal audits. Our FQHC 340B Compliance team recognizes the everyday struggles covered entities face in conducting regular audits, whether it be a challenge in identifying a responsible staff member with the right knowledge and skill set, or a challenge in continuing to prioritize self-audits when competing organizational needs call on the time of the responsible staff member. To alleviate this stress, our team collaborates closely with health centers to work as an extension of the organization, ensuring that comprehensive monthly internal audits continue regardless of competing priorities.

The importance of monthly audits is underscored by the limited lookback window for changes in 340B qualifications, provided by third-party administrators (TPAs) or pharmacies. With lookback periods as short as 30 days, FQHCs must verify the eligibility of prescriptions regularly so that any claims that were incorrectly qualified as 340B eligible may be reversed in a timely manner, without necessitating reconciliation with the manufacturer. Additionally, regular and timely evaluations of claim eligibility allows early detection and correction for any systematic processes that may be contributing to compliance risks. Our team of experts conducts thorough internal audits each month, ensuring adherence to 340B statutory requirements, including eligibility, diversion, and duplicate discount prohibitions.

In addition, our team ties each of the prescriptions we review back to HRSA’s patient definition to ensure they demonstrate complete 340B eligibility. We also ensure the audible records are consistent with what the auditors are looking for in a HRSA audit. Another critical aspect of the internal audit involves checking for Medicaid duplicate discounts. Our team reviews all claims processed during the month to test for Medicaid duplicate discounts. We accomplish this by looking at the payers for clinic administered drugs and billing numbers used in the pharmacies to see if any align with the billing information for Medicaid Fee-For-Service (FFS) and Managed Care Organization (MCO) plans. If any are identified and the entity has elected to carve-in, we confirm the state’s requirements to prevent duplicate discounts have been met. If Medicaid claims are identified when they should be carved out, we work with the health center, the TPA, and the pharmacy to correct the claims in question and update the exclusion criteria to prevent future qualifications for Medicaid claims.

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Optimization of Your Health Center

Financial Analysis and Review: Navigating the financial complexities of the 340B Program is daunting, especially with diverse vendors and replenishment models. In contract pharmacy arrangements, these can involve the distribution of 340B savings to the covered entity immediately upon claim qualification, or once the qualified drug has been replenished. The 340B savings may be paid directly to the covered entity from a contract pharmacy, or may go through the TPA with dispensing and administrative fees deducted before passing along the net savings to the health center. Due to a plethora of factors, accounting can become challenging. Our team assists with journal entries, helping manage the intricacies of accounting for 340B, particularly in contract pharmacies, to ensure your books remain organized. 

E-Prescription Review: Overlooking e-prescription data can lead to missed opportunities within the 340B Program. FQHC 340B Compliance conducts a comprehensive review of all prescriptions, identifying areas for improvement and opportunity, such as additional contract pharmacies or refining prescribing habits. This proactive approach enhances the capture of eligible prescriptions in the 340B Program.

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340B ESP Uploads and Support: For health centers ready to participate in Second Sight Solution’s 340B ESP Program, FQHC 340B Compliance shoulders the responsibility of managing contract pharmacy designations and claim data uploads. This includes collaboration with manufacturers, wholesalers, and TPAs to optimize pricing and maximize savings for health centers.

Ensuring Program Success: The ultimate goal of the 340B Program is to stretch federal funds for safety net providers and serve patients effectively. Our team emphasizes optimization as a critical element of a client’s Monthly Coordinator Service. This involves pulling utilization-based financial data for each pharmacy location, providing a valuable indicator of program performance over the month. Financial forecasting helps health centers identify issues in advance, allowing for proactive management of contract pharmacy operations. For example, we identified a pharmacy transition which had caused claims data to stop flowing through to the third-party processor before the TPAs even realized they were missing the data. It is important to note that although the financial forecast we provide does not necessarily align with payments you will receive from your TPAs, it does allow you to keep a close watch on your 340B Program’s function and make informed decisions about Program growth or changes.

By including 340B Program optimization in our Monthly Coordinator Service instead of requiring entities to contract for it separately, we ensure that health centers receive continuous support in refining their programs, adapting to changes, and maximizing opportunities without additional charges based on a percentage of savings realized. We help answer questions such as, “Are they partnered with the right pharmacies in their area?” and “Do they have an opportunity to open up an in-house pharmacy based on their patient mix, clinic size, and prescriber volume?” Our team is interested in pursuing what is best for your health center, and our Monthly Coordinator Service embodies everything you need to do just that.

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FQHC 340B Compliance’s Monthly Coordinator Service is a comprehensive solution designed to address the evolving needs of FQHCs in maintaining ongoing 340B compliance. By combining monthly internal audits, financial analysis, e-prescription review, 340B ESP support, and optimization, our team empowers health centers to navigate the complexities of the 340B Program seamlessly. For health centers committed to maximizing their impact and serving their communities, our Monthly Coordinator Service emerges as a valuable ally in the journey towards 340B compliance excellence. Partner with FQHC 340B Compliance today.

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^{FQHC 340B Compliance is the dedicated partner for Federally Qualified Health Centers seeking assistance with the 340B Program. Their mission is to provide the necessary resources to secure and optimize the 340B Program, enabling health centers to offer more comprehensive services to those in need. With a focus on improved compliance and oversight, they act as more than just consultants or automated systems, tailoring their services to meet your health center's unique needs. Visit their website, call (760) 780-7469, or email admin@fqhc340b.com to learn more about FQHC 340B Compliance and how they can help your health center thrive.}