Federally Qualified Health Centers (FQHCs), Ryan White HIV/AIDS Program grantees, and other “covered entities” participating in the 340B drug pricing program often rely on contract pharmacies and 340B administrators (sometimes called third-party administrators, or “TPAs”) to carry out their mission, deliver discounted drugs to their patients, and ensure compliance with 340B program requirements. These relationships can be efficient and rewarding when properly understood, monitored, and structured, but missteps can be disastrous.
The majority of 340B program audit findings issued by the Health Resources and Services Administration (HRSA) and its Office of Pharmacy Affairs (OPA) for diversion and duplicate discounts involve contract pharmacies. The findings almost always are the result of the covered entity not fully understanding how its contract pharmacy and/or 340B administrator applies program rules. Covered entities can be surprised to learn that they are solely responsible to the government for compliance and that many contracts proposed by contract pharmacies and 340B administrators leave them with little or no recourse against the vendor.
FTLF offers this day-and-a-half intensive training as a comprehensive dive into 340B program contract pharmacy and 340B administrator arrangements. Attendance is limited to a small group of covered entity representatives. FTLF attorneys will cover these topics and more in our custom training and education center in Washington, D.C.:
- Mastering the mechanics of preventing diversion and duplicate discounts, including possible blind spots and pitfalls;
- Getting the most out of your contracts with contract pharmacies and 340B administrator arrangements, including the protections you need;
- Understanding the various ways in which covered entities compensate contract pharmacies and TPAs, including compliance concerns with some approaches;
- Discussing real-world examples of agreements and disputes using FTLF’s decades of combined experience representing 340B program covered entities; and
- Implementing best practices and policies and procedures to prevent missteps
- 340B Covered Entity Executive Staff
- Financial Leadership
- Pharmacy/340B Staff
- Legal/Compliance Teams
After this training, you will be able to:
- Identify contract terms that put the covered entity at compliance or financial risk;
- Understand the mechanisms used by contract pharmacies and TPAs to identify eligible 340B claims, ensure that payers and Medicaid are billed correctly, and manage 340B program inventory; and
- Review and improve existing policies and procedures to reduce 340B audit risks.