340B

340B Legislation Update Notes from ASHP Summer Meeting

I have just finished attending the ASHP Summer Meeting in Baltimore. It has been time well spent. I attended as a state delegate, but will not bore you with those notes, rather the Monday 340B Legislative update notes that I jotted down. We heard from the OPA director, the OPA Deputy Director, and a pharmacy director from an audited hospital.

CDR Krista Pedley, OPA Director: What I took away from her presentation (and was a constant theme, of which I have mentioned before, so it is not new) is the need for policies and procedures defining how we manage and administer our 340B program. You should have a policy or procedure that defines a covered patient, how you define an inpatient versus an outpatient (she also made the point that this should be consistent for all patients and not something you do just because of 340B, otherwise it is a red flag), and policy and procedures around all processes related to 340B. You will be asked about duplicate discounts, so make sure you know how your site prevents duplicate discounts from happening. The auditors will check on the Medicaid exclusion file. One great piece of information she shared was that the OPA does have an audit document they follow (so audits will be consistent), however, it is a fluid document and can change as the OPA learns from audits. This document will not be shared, but she said they will post a one page document on the process on the OPA website in the next couple of weeks. How many audits is the OPA doing this year? They have identified 45 sites to audit (some criteria are used to identify sites at greater risk). The OPA will notify you in advance and provide a list of items you can prepare ahead of time (I will share the list provided by the audited site in a few paragraphs). Krista’s main message was to follow these 3 words: Responsibility, Compliance, and Accountability.

Michelle Herzog, Deputy Director of OPA: She shared some similar messages as Krista did and added the following relevent items. We will receive a letter knowing they are coming. They will check contract pharmacies and ask for policy and procedures related to management of contract pharmacy (so you need to have some in order to give it to them). They will test 340B transactions via sample. This will be a beginning to end approach and you will need to provide data and information so they can validate this (which can be tricky for sites using paper records). Finally, she said that they will conduct an exit interview.

Denver Health (an audited 340B hospital): Here are the items that were requested prior to the audit: 6 months of prescription data (this was 450K prescriptions). All policy and procedures related to 340B at your site (once again, you need to have them to give it to them). List of 340B clinics. Medicare cost report. A scheduled room with multiple projectors. I thought the multiple projector thing was odd, but he explained that presenting multiple documents side by side on the projectors was critical for speeding the audit process along. The audit took about 3-days, and the OPA will work with you on days that are best for conducting the audit. A tour of the facility. And the last thing mentioned was 50 specific examples for encounter to dispense of 340B medication.

Well, I will be heading back and looking at our policy and procedures and completing a gap analysis to identify where we need to strengthen or create policy and procedures. The idea is to be in constant readiness so that in the event you are audited, you can feel confident that you will be okay. Don’t get me wrong, you will still have anxiety and stress, but less of it. The OPA did say that this is not meant to be punitive (although, there are penalties if you are non-compliant or committing diversion or duplicate discount). Still a great program that can ultimately benefit patients and healthcare in general through healthier patients who are more compliant on their medications. One last thing, I did hear Krista state is that Apexus is “Amazing.” It was in relation to the 340B University that Apexus provides for free (you do need to cover you costs for getting to the education of course, but they do not charge for the education). I just wanted to get that down for the record. Done!

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Senator Hatch has a draft bill to exempt 340B discounts and Medicaid rebates for drugs in a shortage

Does this feel like de ja vu? If you are a member of this blog, you may have read the article from November 24, that introduced three senators who were inquiring and considering drafting legislation on this subject. Well, at least one of them is no longer considering it, he did it. Senator Hatch, who I have actually met and seems to be a pretty good guy, has in fact presented some draft legislation that provides a 7-year exemption from 340B pricing and Medicaid rebates. This exemption period is from January 1st, 2013 to January 1st, 2020. Initially the exemption was going to be for medications that are in short supply. My initial concern was how do we ensure a drug company does not create a shortage in order to obtain the exemption (I believe most companies wouldn’t, but I firmly believe some companies would). The new legislation is more specific about what drugs can become exempt, and it is for injectible drugs that do not have market exclusivity (generics) with 4 or fewer companies making the drug. This seems like an awfully broad group of drugs. In addition, many of these are used on inpatients and not in outpatient. I still feel there is room for collusion with drug companies to get the market down to 4 or less companies in order to receive the 340B and Medicaid rebate exemption. I also feel that many drugs that wouldn’t even go on shortage would fall under the exemption, which does not make a lot of sense.

Our colleagues at the American Society of Health-System Pharmacists (ASHP) have collaborated with many organizations, including Apexus/PVP, to draft a letter to Senator Hatch addressing our concerns. I think it does a great job at detailing the concerns we have with the bill. I do like the fact that Senator Hatch is engaged with trying to fix the problem, however, it is likely that advisors to the bill may not have looked at the issues from all angles. Providing such broad pricing exemptions instead of identifying a mechanism to make it possible to pinpoint needed critical drugs seems a bit like using a hatchet (pun not intended) instead of a scalpel. At minimum, there will be unintended consequences that could result in significant cuts in 340B savings and State Medicaid savings that have very little to do with the drug shortage issues. In fact, as a pharmacy director of a 400 bed hospital, I doubt that the proposed legislation would positively impact the drug shortage, rather it would just help drug companies increase profits. It is even possible that we could create drug shortages due to the potential of adversely incentivizing companies to collude in reducing the number of companies making a drug in order to fall into the exemption. That would be a travesty.

As with the previous article, I am asking Senator Hatch to please consider the issues being brought to his attention by the group from ASHP. I sincerely believe that the current exemption idea is not a plausible solution to the drug shortage issue. I live in the state of Utah and feel we need Senator Hatch’s experience in Washington. He is a ranking member of the Senate Finance Committee, and at a time when we are seeing a lot of turnover in the Senate and House ranks, we need to keep some experience in place. However, I could not endorse Senator Hatch when bills that do not make sense are sponsored. We need you Senator Hatch, please make the appropriate edits to this bill.

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Apr
19th

340B Recertification Dates are Emailed

We have our recertification dates!

I have been stressing a little about my hospital’s DSH percentage, and I am happy to announce that our DSH% came back above the 11.75%, so we are good to go for another year. We also received the preliminary informational email on recertification yesterday from the OPA. Here is a copy of the critical part of the email:

Recertification Dates by Hospital Type:
• 04/20/2012 for Free Standing Cancer Hospitals, Children’s Hospitals, Rural Referral Centers and Sole Community Hospitals
• 04/27/2012 for Disproportionate Share Hospitals (this is my type of hospital)
• 05/04/2012 for Critical Access Hospitals

Based Upon Hospital Type the following should be available to the Authorizing Official for recertification:
• Last Filed CMS Cost Report
• Annual CMS Cost Reporting Period (eg, 01/01/2012 to 12/31/2012)
• Allowable disproportionate share adjustment percentage (DSH%)

Recertification Process Highlights:
• Advance Notification Will be received 1-2 days prior to the start of recertification to both the Authorizing Official and Primary Contact of the Parent Hospital
• On the start date of the Hospital Types recertification, only the Authorizing Official will receive a user name and password to recertify/decertify all eligible child sites
• The Authorizing Official will only be required to recertify/view Parent/child sites that have been in the 340B Database for at least 12 months
• Any site with a future termination date will not be required to go through the recertification process.

Please be aware that hospitals failing to participate in the recertification process or that no longer meet the program requirements will be removed from the program. It is essential that all covered entities maintain up-to-date and accurate information in the 340B Program database. Covered entities are responsible for ensuring that their eligibility information is accurate and up-to-date. HRSA OPA will review all hospital recertifications this spring. HRSA reserves the right to request additional information to verify the 340B Program integrity requirements.

OPA will send reminders and more information about recertification requirements. Questions regarding recertification may be directed to the Pharmacy Services Support Center (PSSC) Help Line by calling 1-800-628-6297 or by sending an email to 340B.recertification@hrsa.gov.

It is nice to have the dates so we can plan accordingly. As mentioned previously, once your authorizing official receives the recertification email, you have three weeks to recertify. If you have any questions, I do recommend you call PSSC as above or Apexus. We are also able to help you, so drop us an email as well (use our Contact Us page).

Apr
4th

340B Recertification Update – Dates Changed

The expected recertification dates for 340B hospitals have changed

First, the recertification process is still going to happen. Initially, we were told it would be the first and third weeks in April that we (hospital authorizing official and primary contact, my CFO and me respectively) would receive emails from the OPA requiring covered entities to recertify 340B eligibility. The dates have been moved back by a couple of weeks and now we will receive the emails in the third week of April and the first week of May. Once you receive the emails, you have 3 weeks to send in your recertification paperwork.

This is great news for me. When you recertify you need to have your final cost report DSH percentage. The problem we have is that our final cost report will not come out until early May. This means we may not be able to submit an actual number, rather a conservative estimate (which is always lower). This estimate could be lower than 11.75% and cause our facility to have to register with a lower than 11.75% DSH.

I am definitely hoping we receive our emails in May. This should give us the time we need to calculate our final DSH percentage for recertification.

Mar
30th

340B Charity Care Voucher Program Update

We have started our 340B charity care voucher program

As a reminder, we have been looking for various ways to expand and increase charity care to patients in need of help with medications. My pharmacy resident worked on a project to create a voucher program that our hospital based clinics could use to help patients in need of medication cost help. She created a voucher that our outpatient diabetes clinic could use when they identified a patient in need. We have a lot of high insulin need patients, they can use more than 10 vials of Novolog a month. Some insurance plans do not cover this cost very well, and some patients do not qualify for Medicaid and do not have medication insurance coverage. These vouchers could then be taken to our outpatient pharmacy for free or for a very low co-pay (eg, $5 for a month supply of Novolog regardless of quantity).

We started our voucher pilot about a month ago. I recently checked to see how it was going. My out patient pharmacy manager had some very interesting things to say. He said that the patients utilizing the voucher program have been so grateful. He said he has received many thank yous and kind remarks abut the help we are providing. Our hospital also has a charity program for Emergency Department patients, and he said many of these patients are not as thankful and often act entitled to free medications (often complaining about having to wait). I don’t want to paint the world with a large brush, but I think I have an answer for why this is. Patients who go to a clinic and are engaged in their healthcare, genuinely appreciate financial help and take accountability for their health. Patients who frequent emergency departments for non urgent needs are often looking for a handout and are taking advantage of hospitals because we do not turn away patients.

From our Diabetes Clinic, we have been asked to expand the drugs on the list for the pilot and they shared the following information as well, “We are having a great response, even bringing people to tears, as we are telling them about the program.” I cannot begin to tell you how good it makes me feel to know that we are impacting patient’s lives for the better. I know one of our patients was paying about $500/month for his insulin. This is extremely difficult to pay every month and can lead to self rationing and under dosing in order to stretch the time needed between fills. Leading to higher HgA1Cs and increased risk of comorbidities and ultimately more overall cost to healthcare.

If you are a covered entity, please look at what you are doing to expand charity care for your patients and your community. If you have a story to share or something you are doing to expand charity care with 340B savings, please send it to us so we can share it on the blog.

Last day of the conference, our brains are maxed out (I know this is a high pitch, bring it if you can!)

340B Conference Beach ViewAlright, I am already back home and had a good nights sleep. The 340B conference was fantastic and we learned a ton. Our road trip home and nights at the conference were filled with great discussions on all things we need to do as a health-system to make sure we are ready for an audit and moving forward safely with our contract pharmacy expansion. We had to leave a little early on Friday due to the flight out of Longbeach, but we did catch some of the earlier sessions. I’ll cover that then go from there.

Billing and Duplicate Discounts:
-MCO Medicaid Rebate Expansion. In current medical reform laws, there is language that will expand Medicaid rebates to MCO or managed care Medicaid. I have one word, $%^& (pick whatever you want). I have been thinking about the consequences for this, and depending on how much managed care Medicaid you have in your state, this may/will create some significant process changes, which may simply include more carve-out and less 340B savings.
-State Medicaid Policies. In a June 2011 OIG report, it states that CMS should require states to create 340B policies. I completely agree, the issue goes back to “the right level of sophistication.”
-Medicaid Partnership. It sounds like everyone is doing a slightly different thing with their Medicaid. The optimal situation is for a win-win partnership. The covered entity purchases Medicaid 340B patient drug at the 340B price and passes some of the savings on to Medicaid. This amount should be more than they would have received on rebate, but not all of the savings. The covered entity should be able to retain some savings and therefore create a win-win and not duplicate discount the drug manufacturer.
-Medicaid Exclusion File. This file on the HRSA website is the “official” data source to protect duplicate discounts. As a covered entity or Medicaid staff, this is where you need to look to make sure you know what sites need to be excluded from rebate requests.
-Quote for the day: “AWP, Ain’t What’s Paid” (I think it was Chris Hatwig again). This was part of a discussion on new calculations for billing and reimbursement from Medicaid. Huge, huge impact if it goes through. This will be a topic for future discussion. Rich B is working on an article to explain how in the world the 340B price is calculated. It is a very convoluted calculation. But a rough estimate of the cost discount for 340B is 49% of AWP.


Closing Thoughts:
We had a lot of fun at the conference, met a lot of great people, and learned a ton. I have shared with you the highlights, but would love to see you at the next conference. This is not a completely altruistic request. The more people that go and learn how to safely, appropriately, correctly, administer the 340B program, the greater the possibility that the program is not discontinued due to gross negligence. So you see, the fate of the program in part lies with us.

I am still learning and look forward to the great things we are planning for the program (projects to directly improve patient care and expand charity care, which will result in improved health for patients and decreased overall cost for healthcare as a whole).

Over the next few months, the Richx2 and I plan on focusing on a few key elements that we have learned about. Some of the topics we presented in these few posts will be expanded upon as well. To study and learn creates a certain level of understanding, but to teach and present it will hopefully benefit you and us.

Special thanks to Lance and Victoria with the American Healthcare team. We look forward to working with you in the future.

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Mar
1st

340B Conference Day 2 Hospital Breakout and PVP

340B Conference PVP/Apexus website information and Hospital Breakout


(The pic is of Rich and me listening to the afternoon session (about 5 pm). It was a panel of mostly lawyers)

Quote from Chris Hatwig, VP of the Prime Vendor Program;

“Pay careful attention, be conservative with the program [340B].”

I can’t echo enough of what Chris is saying. If you are not sure that what you are doing is okay, then be conservative. The audit information presented so far has been eye opening. Do not put yourself in a situation where you need to explain, rationalize a decision you made that is questionable. We all want to maximize our opportunities, but we need to do it in a safe and conscientious way.

Navigating the Apexus/Prime Vendor Program (PVP): I have been able to meet and speak with many staff members of Apexus/PVP. This is a class-act organization that is stepping up their efforts and doing a lot more than just contracting better prices for us. My hat goes off to the folks at Apexus, read on to see why.
-First, if you are a 340B facility and not signed up with PVP, then you are probably missing out on a lot of additional discounts. To say it in a different way . . . sign up for the program. PVP is the exclusive contractor for the HRSA 340B program. I always think of it as the GPO for 340B, but that would be very bad semantics, as you can’t use a GPO with 340B. PVP has been able to negotiate over 4500 sub-340B prices, and other items such as labels, bottles, vaccines, glucose management meters and strips.
-Signing up, on the main PVP website has a link on the first page. You click on the link and sign up. If you are already a PVP participant, then you can request a username and password. This will add additional features for you. My favorite is the catalog (you also get the reports). The catalog will let you look up pricing for all the products in PVP.
-Reports, in the session they shared a bunch of report features I have not used before. One I will be using is “Best Buys.” It breaks down best buys by category/class. Shareback report, since PVP is not for profit, they share back any NOI above allowed carryover (otherwise known as profit in the for profit sector).
-Apexus Answers, currently PSSC is focusing their assistance efforts on the new covered entity types (not hospital). If you need 340B program assistance and PSSC has told you they can’t answer your call at the moment, try 340BCustomerService@340bpvp.com.
-Navigating 340B, if you have staff or students and you want to provide a nice primer on 340B. Have them go through “Navigating the 340B.” They will do a quiz at the end and if they pass 13 of 15 questions they will receive a certificate they can print.

DSH Stakeholder Section: I am always concerned at how much to share of this section. Nothing is a secret or anything, but at this part of the conference, the attendees are asked if they are from industry, contract pharmacy, etc. Every group type has its own breakout section. Most of it is sharing and an opportunity to ask tough questions that you might not ask with all stakeholders in the room. So, this will be short and cover some good guidelines that I felt were shared. Once again, another great reason to go to the conference versus reading my cliff notes.
-Preparing for an audit ideas. 1) Create an introduction presentation for the audit team. It is a good strategy because it keeps you on the offense, versus waiting for the audit team to ask for things. 2) Create a 340B Audit Team. Determine in advance who should be on the team (eg, pharmacy, accounting, legal, administration, public relations). 3) Work with Medicaid, many states do not have a Medicaid with the “right level of sophistication” [when it comes to understanding 340B]. (one of my favorite quotes of the day)
-Medications given prior to admission. Are they considered outpatient or not? There was no answer on this. Here is an example, patient shows up in ED and receives medications (current status is outpatient). The patient begins to deteriorate and is admitted to the medical unit for a complete workup (status is now inpatient). At my facility, all of the medications for the encounter are considered inpatient and not accumulated. We look at all of the ADT data for a specific patient encounter, if there is an inpatient status anywhere in the encounter, then we exclude it from the 340B accumulator feed data. Remember Chris’ comment at the beginning of this article, be conservative. It sounds like sites are doing it both ways. My concern is that this leads to potential diversion of outpatient drug to an inpatient, especially because when drugs are given and when a patient is transferred in the system where the data resides do not always line up accurately. As the saying goes, when in doubt, throw it out! In the end, we did not get an answer as to what is right, there is simply no specific guidance at this point. During an audit, you will need to explain why you do what you do, so which process will be easier to explain?

340B Conference Day 2 Morning Session

340B Conference Del Coronado
Legislative Update: Ted Slafsky (CEO SNHPA) and Mike McCaughan (Editor, The RPM Report)
-Drug shortages, no legislation introduced yet (see our previous article on this issue). Some lawmakers are considering legislation on 340B exclusions, and adding the legislation to this year’s Prescription Drug User Fee Act (PDUFA), it should pass this year (PDUFA is sunsetted every 5 years, and this is the year).
-User fee, 0.1% or one penny per $10 spent on 340B drug (collected by manufacturers at time of sale). This was passed by the Senate for 2012 budget, but not the House. For the 2013 budget, this fee could go up to 0.5%. This is used to fund the OPA. Not sure if this will pass for 2013 budget as well.
-The 340B Improvement Act (HR 2674), 38 cosponsors (even between both parties). Extends the 340B pricing to the inpatient setting. Repeals orphan drug restriction for new entities.
-PPACA, is a win for pharmaceutical industry (more prescriptions because of more coverage). Supreme Court is giving this 6 hours (versus the normal 1 hour), and will likely have a decision in June/July. Two key issues are 1) individual mandate and 2) Medicaid expansion. This is not all or nothing.
-More PDUFA changes this year, it is like a Christmas tree that lawmakers want to hang their ornaments (issue of interest) on. Generic drug user fees are being added. Biosimilar process fees.
-FDA dilemma, they are asked 1) why can’t we get some drugs, and 2) how can you let the errors happen. They are getting hit with issues that come from opposite sides that conflict with each other.


Federal Government Update:
-PSSC, they have been focusing efforts with the new HRSA grantees. This is why DSH hospitals have received messages that they don’t have enough resources to respond to their questions. Apexus/PVP has expanded their call center to fill this gap.
-Apexus, has a 340B University and a Peer to Peer program. Strong recommendation to take advantage of these resources.
-340B Audit question, who is conducting the audit? It is the government, specifically HRSA.
-340B Audit more follow-up. Minimum of 6 sites per month will have in person audits. MAKE SURE you have SOPs in place that describe how your 340B program will be managed. You NEED to address diversion and duplicate discounts in your SOP(s). Risk factors for being audited: DSH facility (dang it!!!), Contract Pharmacy (dang it!!!), and time in program. So, I think I will just go ahead and plan on being audited. See HealthcareCommunities.org for sharing of SOPs and 340B information.
-DSH Recertification date, when your authorizing official signs in to the recertification site, they can only do it once. The dates are April 9th and 23rd, hospitals will get either one (they are breaking it up due to volume). The Authorizing Official may get a call to validate the information on the recertification, which may include your Medicare Cost report.


Program Integrity Audits:
-Shands Jacksonville Medical Center was first to be audited. Focus of audit was centered on diversion and duplicate discount. HRSA does verify with Medicaid that duplicate discounts are not happening. This means your Medicaid staff will need to be able to speak to this and be able to provide documentation.
-SNHPA Audit Information. Almost 1/3 of hospitals are now 340B. GAO questioned if all of these are really need 340B pricing. To prepare for audit: create/update 340B policy and procedures, conduct your own internal compliance audit, update your OPA information in the database, use SNHPA 340B checklist coming out soon (thanks SNHPA).
-GSK Perspective (manufacturer perspective). Looking at Rx Level data to see if a 340B pharmacy ID number is being submitted by Medicaid for rebates. Looking for unusual purchase patterns (eg, no inpatient purchases or primarily inpatient product being purchased outpatient). For large purchases, especially penny buys, asking for verification that it is actually on a shelf (so, if you are pre-purchasing 340B drug, make sure you have it in your inventory).
-340B Manufacturer Auditor Perspective. Manufacturers have to use an outside company to conduct audits. Typical process is to notify covered entity (CE) of suspected non-compliance. Based on the CE response, a determination is made whether to continue with the audit or not. If audit continues and non-compliance is determined, then they can pursue dispute resolution. Audits are conducted based on government auditing standards. P.S., policies and procedures came up again (are they trying to tell us something?).

Mar
1st

340B Conference Day 1 (Contract Pharmacy Workshop)

340B Purple Cow - Be Different

340B Contract Pharmacy Workshop

We attended the Contract Pharmacy workshop on Wednesday and really enjoyed the diversity of presentations. I should point out I woke up at about 5 am this morning and am irritated by this fact, since I could have slept in for 2 more hours. With the time change, this is the time I would have normally got up, but alas, here I am. So, why not share what I learned yesterday.

One of the first presentations talked about the fact that a contract pharmacy can be more than a retail pharmacy. Bells and lights went off in my head . . . Homecare!!! I looked over at my colleagues and told them my epiphany, and they agreed. So, more work to do when we get back to look into this (we weren’t busy already).

It was really nice to hear from people running the contract pharmacy, versus the covered entity. Here are some of the highlights of what they felt are important concerns from the contract pharmacy perspective (so, if you are a covered entity, you really should consider these issues and make sure you can address them or at minimum warn a contract pharmacy of these potential outcomes):
-Inventory swelling (as a pharmacy waits for replenishment, they will most likely need to reorder the drug as well. This could lead to an increase in inventory on hand (as a result, possible decreased turns)
-No interest loan, because pharmacies are fronting the drug up front, this is sort of a no interest loan that will not be realized until the end of the relationship (when they finally sell the remaining balance). This is even more of an issue for a closed door pharmacy that may not have patients that will buy the last round of meds at the end of the relationship.
-Purchase volume drop, since some of the current prescription volume will go to the 340B purchase, the pharmacy does not purchase the drugs. This could lead to decreased volume for the pharmacy (also impacting turns).
-Replenishment rate, if the covered entity is replenishing weekly or even less often, this adversely impacts the pharmacy since most pharmacies replenish daily (or even two times daily). Recommendation: replenish daily if you can.

We are in the middle of contract negotiations with one drug chain and one software vendor for contract pharmacy services. I cannot go into details because of this, but one important tidbit I heard from Bill von ,from SNHPA, was that contract pharmacies taking percent fees (versus flat rate) are higher risk. For the record, he didn’t say you can’t, just that it is higher risk. This actually came from an OIG opinion No. 98-15 (12/2/98). If you do a percent fee, then he said one option is to cap it. The reason is profit sharing. The intent of 340B is to help the covered entity, a contract pharmacy should be made whole and make a little more than they would otherwise to cover their time and effort (since administering a 340B plan can be a pain).

The Purple Cow? One of the speakers mentioned that a pharmacy needs to be a purple cow, in otherwords unique. Asking it in the sense of, what is your purple cow? How do you look different than the thousands of brown cows around you? Services that a pharmacy can provide to obtain “Purple Cow” status include (but are not limited to): medication delivery, durable medical, patient charge accounts, compounding, and assisted living and nursing home services.

Alright, it is now 6:30 am and I am going to do some work emails and get ready for the day. Please let me know if this is helpful. Once again, you should come to the conference if you can. It is great to get a feel for what people are doing and to network. I also want to thank Basil from Walgreens, we had some great discussions yesterday.

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Feb
29th

340B Conference Road Trip

Our 340B Conference Journey has begun

We have offically begun our 340B conference journey. I plan to update this site with critical things we learn at the conference. Let me just say, it will be better for you to come live if you can. This conference provides so much critical information that we cannot cover in post updates, but we will try. It also provides networking opportunity with vendors and other covered entitity staff that is invaluable for improving what you do at your site.

340B Conference Journey
Currently about to start the pre-conference Contract Pharmacy workshop, but want to share our road trip (mostly because it is funny and I want to give Rich B some grief). We decided to save our company money and fly into Longbeach for $200, versus San Diego for $500. This requires a 2-hour drive, and with three of us, this should provide a greater than $800 cost savings when you take into account gas. Here is the fun part, I volunteered to ride in the back seat (since corporate is paying for the rental car, thanks T). Rich B is co-pilot. We left our home state at 6:20 am and we are fairly tired. Rich has not had his coffee yet, and sends us north bound on I-405 right off the bat. For the record, San Diego is south bound, not north bound. Here is a pic of Rich B acting as co-pilot (we got him a coffee). Rich wants me to add that “For the Record, we made it!”

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