340B Drug Pricing Program
The 340B Drug Pricing Program, created through the Veterans Health Care Act of 1992, requires drug manufacturers to provide discounted outpatient drugs to covered entities, allowing them to stretch scarce federal resources, reach more eligible patients and provide more comprehensive services.
As reimbursement cuts or savings occur, it’s important to recognize the program is still critical at facilities, regardless of new requirements.
BKD assists providers with all aspects of the 340B Drug Pricing Program. Our national team has the technical skills to help provide quality compliance services, best practices and tailored insight. We understand the financial demands facing health care providers and can help offer practical compliance and operational recommendations that go beyond the basic service approach.
Independent 340B Audits
It’s increasingly important to have accurate, complete and auditable records to maintain compliance and identify the program’s key risks. That’s why BKD performs independent external 340B audits for covered entities throughout the country. Our process helps to review multiple aspects of 340B—from policies and procedures to eligible dispensations—identify additional program opportunities and risks and help entities create precise and compliant audit trails. These procedures are designed as a mock audit that simulates a Health Resources and Services Administration (HRSA) audit.
BKD’s 340B team has the expertise to provide operational knowledge and recommendations that help covered entities increase savings and maintain compliance. Our team has experience with most split-billing vendors, wholesalers and billing systems, and we understand the complexities of building and maintaining a 340B program.
Clients request our help with many different aspects of their program, including—but not limited to—registration assistance, policy and procedure development, child site review and maximization, development of contract pharmacy arrangements and split-billing software implementation assistance and operational improvements.
BKD can help provide continual monitoring, which enables 340B-covered entities to assess risk associated with compliance, test split-billing software and perform a review of 340B accumulation factors that potentially reduce savings. Continual monitoring also is needed for covered entities that have self-reported compliance issues and are required to pay back savings to a manufacturer. The process allows these entities to continue purchasing 340B drugs, repay manufacturers and get back on track for 340B compliance.
As the 340B Drug Pricing Program expands, it’s under continued scrutiny for payment reform and legislative changes. BKD’s Washington, D.C., perspective on industry trends and challenges, along with our extensive health care experience, provides clients with timely legislative updates and solutions for their 340B program.