Your monthly news
Welcome to our newest edition of our e-newsletter. The HCAN Hub is a monthly publication for Nebraska Community Health Centers and their partners. Each month we will have a different focus topic and feature best practices, resources, trainings and much more!
Each month we will be highlighting promising practices from our Nebraska health centers and national training and technical assistance partners. HCAN is proud to share our health centers’ important work, demonstrating impact for health center professionals and raising awareness among our partners. This month we are focusing on 340B/Pharmacy. 

Promising Practices - 340B/Pharmacy
 
This promising practice is shared by OneWorld Community Health Centers, in Omaha, NE

Please give an overview of your work completed:

HCAN offered a unique opportunity to work with a 340B consultant Judy Lapinski. OneWorld's Pharmacy Director and CEO met with Judy via phone and email several times in 2019. HRSA offers best practice suggestions for entities to follow and one of them is having an external review of the program. OneWorld decided this would be a great opportunity to work with Judy to perform this external review.  During the initial meetings we identified areas we would like to focus on as an external 340B review. Those areas included a review of: policy and procedures, operational agreement for Contract Pharmacies, internal audit procedures for both in-house and contract pharmacies and discussion around USP 800.

HRSA offers a check list that includes essential elements that should be discussed within our policy and procedures. Judy also provided us with 12 essential elements on monthly audits. We reviewed our audit procedures and audit templates with these elements to ensure we are looking at all compliance elements.
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Do you have a promising practice you would like to share? Please email Jenna Thomsen at JLT@hcanebraska.org

At this time of year, many of us are looking back at 2019 and looking forward to 2020. As far as the 340B Program goes, although there was a lot of sabre rattling there were very few changes heading into 2020.

2019 Year in Review

Legislative Activity
Specific to FQHC’s, although 340B was mentioned in numerous pieces of legislation throughout the year no major 340B legislation materialized. Because drug pricing is such a high priority, the program remains a talking point however the legislative focus has shifted from 340B to the PBM’s

Price compression
One of the biggest threats to 340B was not government related at all but rather the Pharmacy Benefit Industry (PBM) who has seen 340B as a threat to their rebate revenue stream. In late 2018, CVS Caremark, one of the country’s largest PBMs, sent notices to 340B providers and contract pharmacies notifying them of significant reductions in reimbursement rates. In essence they were attempting to recharacterize 340B pharmacy as non-retail pharmacies, which would allow CVS to reimburse these pharmacies at a much lower rate. After a considerable outcry from a large number of 340B stakeholders and court rulings related to the reduce Medicare payments to 340B Hospitals, CVS Caremark backtracked and announced that it was reversing its decision.
Also, in late 2018, a federal district judge struck down HHS' proposed cuts of almost 30% to Medicare Part B reimbursements for 340B providers stating CMS overreached its legal authority. This decision, however, was appealed and cuts remain in place.
A final hearing was held on November 8 th with a decision expected soon. If the government prevails, we may see Caremark (and other PBM’s) attempt to lower reimbursement for 340B providers.

340B Drug Pricing Website
April 1st, HRSA finally launched its 340B Drug Pricing website, which provides additional transparency and assists safety-net providers in determining the maximum price manufacturers can charge under the program. This implementation was driven by a 2010 law authorizing civil penalties for manufacturers who “knowingly and intentionally” overcharge covered entities. This should be accessible through the Covered Entity’s 340B PVP account.
On the audit front, HRSA suspended uploads of audit outcomes to its website during 2019. The audits continued but between June 21st and October 10th no audit outcomes were posted on HRSA’s website. HRSA states that it was reevaluating its level of authority and oversight of the program.
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Health Action Webinar Recording:
Drug Pricing in 2019 and Beyond
Presented by Families USA

As the 2019 Congressional session ends, the U.S. House of Representatives just passed legislation to lower prescription drug prices significantly. The Lower Prescription Drug Costs Now Act allows the federal government to negotiate lower prices for Medicare, among other reforms. In its wake, many more drug pricing reforms could be on the horizon. On this webinar, we discuss the current state of drug pricing at the federal level and what is to come.

Watch the recording or download the slides here.
Quarterly 340B Program Registration
Quarterly 340B Program site registration is open from January 1 to 15. Health centers will still be able to register a site that has been verified as implemented and with a site status reflected as “active” in EHBs Form 5B through February 21. After that date, the system will close to prepare for the April 1, start. Email the 340B call center at apexusanswers@340bpvp.com or call 888-340-2787 (Monday-Friday, 9 a.m.-6 p.m. Eastern) to register a new site or ask questions.

You will need to provide the following information when calling:

• Health center name
• Site/clinic name
• Site IDs for all sites
• HRSA/BPHC grant number
• Contact name and email address
• Authorizing official name and email address

The authorizing official will receive an email message that the account is unlocked and a registration may be submitted.
Manufacturer Notice to 340B Covered Entities
For your awareness, HRSA has posted a new notice on the Office of Pharmacy Affairs Website: Manufacturer Notices to Covered Entities.

Please review and apply to your covered entity accordingly.
Webinar: Addressing the Cultural Dimensions of Pain Management
Wednesday, January 15, 2020
12:00 pm (CST)

Presented by Migrant Clinicians Network

While the assessment and treatment of pain is a universally important health care issue, modern medicine still struggles to agree on a method to measure pain perception. Difference among individuals based on culture, gender, age and a variety of characteristics means that although nearly all people experience pain sensations similarly, studies show there are important differences in the way people express their pain and expect others to respond to their discomfort.

There are often conflicting attitudes about using pain medication. An understanding of the impact of culture on the pain experience is important in assuring effective patient care. This session will review a series of considerations when developing an approach to pain management, addressing some of the most common issues faced by patients and providers.

Signup for the webinar here.
2 day Workshop: 340B Drug Discount Program Compliance












January 22nd and 23rd, 2020

Presented by Feldesman Tucker Leifer Fidell

Worried about an upcoming audit or ongoing program compliance?

Join FTLF for this two-day workshop, designed for staff who are responsible for or closely involved in the operation of a covered entity's pharmacy program. Our nationally-recognized 340B team, Michael Glomb, Jason Reddish, and Noori Ali will help you build confidence and feel better prepared to respond to any compliance concern. 

Who Should Attend?
  • 340B Covered Entity Executive Staff
  • Financial Leadership
  • Pharmacy / 340B Directors, Managers, and Pharmacists
  • Legal / Compliance Teams

Register for the workshop here.
State Legislatures Continue to Tackle Drug Costs in 2020

NASHP has launched its 2020 State Rx Legislative Tracker , which highlights bills designed to curb the rising cost of prescription drugs introduced in statehouses across the country. As of Jan. 2, 11 new bills have been filed and 127 carried over from states’ 2019 sessions. States are taking varied approaches – proposing prescription drug affordability review boards, capping out-of-pocket insulin costs, enacting wholesale drug importation programs, and addressing pharmacy benefit manager practices – as they build on the momentum gained in 2019 when 37 states passed 60 new laws. Explore the legislative actions states are taking in 2020 here .
Please join Dr. Steve Geiermann with the American Dental Association, and Dr. Bob Russell with the Iowa Department of Public Health, for a one-day workshop on Operational Site Visit (OSV) readiness and interdisciplinary, community-based approaches for oral health programs. ADA CERP Continuing Dental Education credits will be available.

Registration opening soon!
Health Center Association of Nebraska | Website
The HCAN Hub is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) as part of an award totaling $745,450 with 0% financed with non-governmental sources. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov.