Senator Grassley statement, sequester impact on OPA, GPO Exclusion clarification marches on, and HgA1C improvement is statistically significant!
The above list has one thing in common . . . 340B. Some of the items are not so good, while at least one is fantastic (in my view). Before we get into the topics for this month’s article, I did want to reach out and see if any of you were able to attend 340B University earlier this month at ASHP SM? I had the opportunity to present “Mixed-Use Settings” and want to hear your input on how I did and what you would like to learn more about. I know I have said it before, but you NEED to attend 340B University at least annually. If you have staff that are critical for your 340B compliance, then they too need to attend 340B University at least annually. We have made it part of our Policy that this needs to take place. In any case, it was great to participate at 340B University and hear a lot of questions and network with a lot of other sites to learn about what they have been doing and what they are struggling with.
Senator Grassley (R-Iowa): I want to start off by saying that I believe the senator has good intentions. He has taken a very strong stance on the 340B program that involves the concept that hospitals are “making sizeable profits at the expense of Medicare, Medicaid, and private health insurance.” SNHPA has in turn responded to the statement by explaining why this is not necessarily the case. I tend to have an opinion (don’t we all have one?) somewhere in the middle. There is potential for impact on insurers (government and private) with the 340B program, and we as covered entities need to ensure we are conscious of this and ensure that we are mitigating any potential issues. One thing I find to be true as we continue to use some of our savings to favorably impact patient care is that through 340B savings and leveraging 340B pricing, we can show positive impact to healthcare in general. At the end of this article I will share some preliminary data presented at a recent pharmacy residency conference related to improving HgA1C in diabetes patients through a 340B voucher program implemented at my DSH facility.
The sequester impact on the OPA is not a small one. The once planned 200 to 400 audits from OPA for 2013 is likely less than 100 now. Our colleagues at OPA are under tremendous pressure to certify, recertify, and audit the covered entity sites in the 340B program. Losing resources to achieve this task did not help. Time will tell if the resources will be replaced and the OPA is appropriately resourced to meet their goals and objectives. I do have to say thank you to the OPA staff, I know the two weeks of open enrollment are extremely busy, and we had a couple of sites and enrollments to complete and they were very helpful in ensuring it was all done correctly.
GPO Exclusion clarification marches on! Well, we are in June and the absolute drop deadline for the GPO Exclusion clarification about triple-split for mixed use areas is on August 7th (2013, just in case you were hoping for a different year). I have said it before and will say it again (although some may call it blaspheme). . . I think the GPO Exclusion clarification is a good thing. Seriously, I do, but it still makes it time intensive and a bummer that I saw a spike in GPO/WAC purchases by $100K in April/May. It does help us (is force us a better word) become more compliant, which is exactly what we all should be doing. The reason I saw a spike in purchase is because I did not have any GPO accumulations for the first bunch of orders, which means you will have WAC/Non-GPO purchases. However, providing you do not shift products around (buy different NDCs), this should shift back down to a lower impact over time. It has also provided me the opportunity (I am sure I can come up with other wording here as well) to look deep into our charge practice to ensure we are billing everything we administer to patients. I know this sounds like a no brainer, but in a DRG type setting you sometimes do not scrutinize billing practices as much as you ought to. I am sure we will discuss this further in future articles.
HgA1c: Okay, now for the fun part. My pharmacy resident presented at Western States pharmacy residency conference some data about our 340B voucher program for patients in our diabetes clinic that could not afford their insulin. For some time we have had many anecdotal stories about the patients we have helped, and it is motivating to hear the positive impact the program has had on our patient’s lives. It is even better now to tie data to it. We saw many patients with pre-HgA1c values that were double digit drop to 7’s and 8’s (for non-clinical folk, that is a good thing). HgA1c represents how controlled your blood sugars have been over the past few months. Scores in the double-digit range for long periods of time will often result in kidney failure, cardiovascular complications, and other macro/micro vascular disease progression. In other words, it is catastrophic for healthcare costs (think of the cost to our healthcare system for kindey failure, amputations, blindness, cardiovascular disease . . . we are talking about some of the highest drivers of healthcare cost) and the patient (these are life changing diabetes related conditions that not only decrease life expectancy, but drastically decrease quality of life). The beautiful part from a research standpoint is that we showed a statistical difference in HgA1c for our small patient population (we needed to have pre and post scores in this short study period). It is likely that we were under powered in the study and still had statistical difference (that is saying something right there). We continue to look for ways to leverage our 340B savings for our vulnerable patients. I strongly encourage you to do the same.
This was a long one, and if you made it this far, I thank you for staying with us. Aloha, -Rob