Contract implementation and compliance are pivotal aspects of contracting with a new 340B pharmacy. Once the contract has been finalized and approved, both the covered entity and the pharmacy must work together to ensure a smooth transition and adherence to the terms of the agreement. This phase involves establishing effective communication, integrating pharmacy services into the covered entity's operations, and diligently following all 340B program rules and regulations. In this blog post, we will delve into the key steps involved in contract implementation and compliance to foster a successful and enduring partnership.

1. Establishing Communication Channels

Effective communication between the covered entity and the 340B pharmacy is paramount for a successful partnership. Regular and open communication helps build trust, facilitates information exchange, and addresses any issues or concerns that may arise during the implementation process. The covered entity and the pharmacy should designate points of contact to streamline communication and ensure efficient coordination.

Communication should extend beyond administrative matters and include discussions on medication ordering and inventory management. The covered entity must communicate its medication needs clearly, while the pharmacy should provide timely updates on medication availability, pricing, and any potential disruptions in supply. Collaboration in communication helps prevent misunderstandings and contributes to seamless pharmacy operations.

2. Developing Processes and Procedures

During contract implementation, the covered entity and the 340B pharmacy must work together to develop standardized processes and procedures that govern medication ordering, dispensing, and documentation. These processes should align with 340B program requirements and ensure compliance with all applicable regulations. Clear and well-defined procedures help streamline pharmacy operations, reduce errors, and maintain program integrity.

Training plays a crucial role in implementing these processes effectively. Healthcare providers and pharmacy staff should receive comprehensive training on the new pharmacy arrangement, including proper medication ordering procedures, accurate documentation practices, and compliance with program rules. Regular training updates and refresher sessions are essential to ensure ongoing adherence to best practices.

3. Adhering to 340B Program Rules and Regulations

Maintaining compliance with 340B program rules and regulations is paramount throughout the contract implementation phase and beyond. Covered entities and 340B pharmacies must diligently adhere to program requirements to ensure the program's integrity and sustain eligibility for discounted medications.

Some key areas of compliance include:

- Patient Eligibility: Covered entities must ensure that prescriptions eligible for 340B pricing are dispensed only to eligible patients who meet the program's criteria.

- Duplicate Discounts: Covered entities must prevent duplicate discounts by carefully monitoring medication purchases and ensuring that 340B drugs are not billed at discounted prices to Medicaid or other federal programs.

- Diversion Prevention: Covered entities and pharmacies must take measures to prevent drug diversion, ensuring that medications purchased at 340B prices are used solely for eligible patients.

- Recordkeeping and Audits: Thorough recordkeeping is essential to demonstrate compliance during HRSA audits. Covered entities and pharmacies should maintain accurate and complete records of all 340B transactions.

4. Ongoing Monitoring and Evaluation

The commitment to compliance does not end with contract implementation. Covered entities and pharmacies should establish a system for ongoing monitoring and evaluation to ensure continuous adherence to program requirements. Regular audits and internal reviews can help identify areas for improvement, address potential issues, and verify that the pharmacy arrangement is delivering the expected benefits.

Conclusion

By prioritizing contract implementation and compliance, covered entities and 340B pharmacies can establish a strong and enduring partnership that optimizes patient care, ensures access to affordable medications, and upholds the integrity of the 340B Drug Pricing Program. A well-executed implementation phase sets the stage for a successful and mutually beneficial collaboration that serves the needs of patients and the community for the long term. The commitment to communication, standardization, compliance, and ongoing evaluation paves the way for a thriving and impactful 340B pharmacy partnership.

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