Big data provides big 340B savings
Being able to transform 340B data into actionable insights is more important now than ever. As covered entities (CEs) try to optimize their program, capture qualified claims and maintain compliance, manufacturers and regulators are restricting 340B pricing. Your data can help you find 340B savings and recover qualified savings, but you must know how and where to find these eligible 340B claims. Here are some FAQs to get you started.
FAQs
The cadence of when you need to review your data and analytics set depends on several things, including how many claims you typically carve in, the size of the team dedicated to your program and how often you’re providing encounter files to your third-party administrators (TPAs). However, the 340B program is constantly changing, so you should regularly review your reporting set and be ready to react quickly. Here’s the frequency we recommend starting with:
Daily-to-weekly: Carved-in claims, carved-out claims and missing files
- We always recommend reviewing claims on a daily or weekly basis. This allows you to understand which claims are carving in or out and flag issues we can help you quickly correct.
Monthly: Prescriber lists, clinic codes, financials, vouchers and self-audit results
- HRSA requires all participating 340B covered entities to perform regular self-audits of their program and maintain historical records of results. We recommend performing self-audits at least once per month. The audit tools in our 340B Clarity portal help make regular self-audits easier and allow you to keep a historical record of audits. Self-audits should include reviewing your prescriber and clinic code lists to ensure the right claims are being captured. For example, if you opened a new clinic or changed addresses, we need to update our rules to account for that new information.
Quarterly: Office of Pharmacy Affairs Information System (OPAIS) records and necessary updates
- Usually, changes to your contract pharmacy network – including adding or removing pharmacies – can only be made during Health Resources and Services Administration (HRSA) registration windows. Review your current information before each quarter to identify if changes are needed and develop a plan for making corrections. To help with this review, we proactively send a client analysis on a quarterly basis a few weeks before the HRSA registration windows to give clients time to review and make decisions.
Yearly: Full program review of financials, methodologies, formularies, etc.
- Your TPAs should have most of this data readily available. If not, they should be able to pull it together for you. For example, we schedule client program reviews every 12-18 months, providing copies of all the reports we present.
- Ad hoc reports: There will likely be occasions where you need one-time or repeating customized reports. These may include uniform data system (UDS), oddity for 340B, HRSA audit, financial reports or ad hoc expansion analyses. The cadence for these reports will vary based on the events that impact your covered entity. We’ll also provide ad hoc expansion opportunities if a different variable is introduced in between quarterly reviews (i.e., new prescriber list, methodology, etc.) Once we understand what analyses you need, we’ll build the files and load in the Report Center of the 340B Clarity portal. These reports are then available 24/7 and can be viewed, exported and shared with other business teams.
You should be reviewing potential program changes in a lower environment to understand its impact on all details and claims. This helps avoid any potential compliance issues, such as diversion and duplicate discounts.
We often hear from covered entities that vendors and partners provide the potential net savings, but there’s no way to do this compliance check, creating a compliance risk.
Any time you wish to make a change in your 340B program, we can show you its expected impact. You have the ability to review each claim down to the penny and verify whether your carve-ins and carve-outs look accurate.
There is no one-size-fits-all in 340B which is why we invested in a dedicated data science team that can handle varying needs for different entity types and sizes. We provide:
- Flexibility: We match our analytics to meet your needs based on the data you can provide.
- Customization: We provide custom and ad hoc client analyses to help you optimize your 340B program.
- Transition expertise: We have experience in working on transitions from all other TPAs, so we know what to look out for and can often proactively address issues.
As experts in 340B data, we can translate any question or problem you have into an answer.