Pharmacy Coordinator (340B)

About the Role

The 340B Coordinator will manage and work with the 340B Program Manager on maintaining the hospital's 340B drug program in an auditable state to include assisting with oversight of covered outpatient drug purchasing, inventory process & dispensing pattern reconciliation, analysis and trending of data, monthly reporting on savings opportunities, and split billing software maintenance.

• Ensure 340B drug purchasing program is in compliance with all regulations and related interpretations.
• Ensure program is fully implemented in all areas of qualified use.
• Audit, review, and monitor utilization records and 340B purchasing accounts to ensure software or tools are working properly and accurately.
• Serve as the liaison for 340B software vendors and wholesale distributors.
• Responsible for maintaining a collaborative relationship with split billing software vendor and wholesaler and provides timely resolution and/or communication of any issues.
• Oversee Quality assurance and audits for 340B participating areas.
• Ensure standard operating procedures are being followed and monitor all drug purchases on the GPO, WAC, and 340B accounts.
• Lead multidisciplinary 340B Workgroup and report to 340B Executive Steering Committees regarding in program compliance and expansion initiatives.

Functional Accountabilities

• Assure all use of 340(b) throughout the institution is fully compliant with all federal regulations and related interpretations for the program.
• Ensure the institution is achieving maximum utilization of 340(b) pricing through full participation in all qualified areas with all applicable products to ensure greatest cost savings returns throughout the institution registries, quality improvement, and studies.
• Ensure that all policies and procedures related to 340(b) include the most efficient use of resources, and other costs of managing, monitoring, and fully participating in the program.
• Coordinate all efforts and personnel involvement with regards to ongoing program operations, compliance oversight processes, audits, data requests, etc.
• Manage drug selection, procurement, inventory control, and coordination of the 340B program.
• Maintain system databases to reflect changes in the drug formulary or product specifications.
• Manage and analyze purchasing, invoicing, receiving, and inventory control processes.
• Continuously monitor product min/max levels to effectively balance product availability and cost efficient inventory control.
• Assure appropriate safeguards and system integrity.
• Coordinate annual inventory and monthly cycle counts with purchasing staff.
• Assure compliance with 340(b) program requirements of qualified patients, drugs, locations, and providers.
• Review and refine monthly 340(b) cost savings report detailing purchasing and replacement practices, dispensing patterns, and internal audit results.
• Monitor ordering processes, integrating most current pricing from wholesaler.
• Prepares and analyzes contract payment reconciliations based on cost reports and payment documentation.
• Serves as intermediary between Pharmacy and Cerner IT for 340(b) related issues.
• Defines financial reporting and information needs and coordinates any systems modifications with IT.
• Monitors and assists in the maintenance/enhancement all third party 340(b) software program(s).

Financial / Contractual Compliance

• Ensure maximum participation with 340(b) program and areas for cost reduction.
• Contribute to development and monitoring of operating and capital budgets.
• Assist with evaluating performance reports and budget variances and developing action plans.
• Conduct/coordinate annual inventory and submits results for review and analysis.
• Responsible for adhering to the prime vendor agreement and contract compliance with the buying group(s).
• Monitor all areas of 340(b) outpatient use and work with purchasing coordinator or designee to ensure maximum participation regarding use of 340(b) priced products in all qualified outpatients where available and appropriate therapeutic or generic choice.
• Monitor for 340(b) pricing exclusions or shortages and establish appropriate alternative products that are included where possible.
• Monitor all outpatient points of service to continually look for additional qualified areas where 340(b) may be used, including potential creative services or disease management approaches that might qualify for covered patients.
• Review of 340(b) account records for exceptions, drugs required to be purchased at WAC, etc., then consider possible alternatives to become standard practice.
• Participate with prime vendor program Apexus/PVP and routinely review 340(b) formulary pricing, potential alternatives, and possible additional savings as a result of GPO formulary.
• Strive to standardize formularies between areas and institutions to achieve maximum 340(b) participating and savings.
• Work directly with manufacturers as well as through GPO and peer professional relationships to determine companies that are contracting with facilities to offer 340(b) or equivalent pricing and develop strategies to maximize such participation.
• Communicate routinely with purchasing coordinator and directors in all areas and affiliated institutions to establish consistent contracts with participating manufacturers.
• Where possible, leverage the purchases of all facilities into these contracts to achieve maximum participation and optimal discounts.
• Based upon 340(b) contracts, routinely review and consider in conjunction with common formularies where clinical data supports therapeutic equivalents and provide recommendations to leadership.

Regulatory Compliance/Quality Assurance

• Responsible for being the institutional compliance expert or authority on 340(b) regarding qualifications to the details, policies, and procedures of the virtual inventory processes required for mixed areas.
• Establish understanding and relationships with finance department to monitor any changes that could affect 340(b) qualification such as changes in the points of service position on the cost report, any changes in institutional ownership or related relationships (e.g joint ventures) and any variations or negative trends in DSH percentages that could potentially affect 340(b) qualification.
• Attend conferences as approved by Division Chief or Business Manager, routinely monitor publications and websites as well as the professional media, literature, and peers to assure the institution has the latest information regarding interpretations, rulings, suggestions, and advanced ideas for improving participation.
• Routinely review and monitor all points of service where 340(b) participation occurs to ensure policies and procedures are followed, entities qualify, and all appropriate patients qualify as covered patients.
• Reconcile utilization records, 340(b) purchasing accounts to insure split billing software or tools are working properly and accurately, perform audits or compliance assessments internally as needed; also coordinate external compliance assessments where appropriate with outside firms to validate internal processes.
• Reconcile / maintain purchasing (financial) records for each cost center where 340(b) accounts apply to ensure the GPO exclusion rule is followed and that cherry-picking or diversion either by area, patient, or drug is not occurring.
• Develop and monitor monthly and annual reports on 340(b) participation which clearly documents utilization, savings, problem areas, exceptions or discrepancies, to be passed to pharmacy leadership and administration.
• Communicates any questions, issues, or discrepancies with the appropriate leadership authority.