340B Contract Pharmacy and Third-Party Administrators
Health centers 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 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 are often 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.
This webinar will cover:
- The mechanics of preventing diversion and duplicate discounts, including possible blind spots and pitfalls;
- Approaches to contracting with contract pharmacies and 340B administrators, including the protections you need;
- Overview of methods in which covered entities compensate contract pharmacies and TPAs, including compliance concerns with some approaches;
- Provide real-world examples of agreements and disputes; and
- Suggest best practices and policies and procedures to prevent missteps
To purchase the on-demand version of this webinar as a standalone, click here.
Please note: This webinar is offered as a complimentary product to all Health Center Compliance Premium Plan Subscribers. To learn more about FTLF's Premium Plan Subscription and to become a subscriber, please email email@example.com.
ELIZABETH "ISSIE" KARAN
Elizabeth is an associate working in the firm’s Health Law and Federal Grants practice groups counseling a diverse array of organizations including Hemophilia Treatment Centers, Federally Qualified Health Centers, primary care associations, and other Federal grantees. Elizabeth’s practice focuses mainly on assisting clients with the 340B drug pricing program, grants compliance, provider collaborations, Medicaid and Medicare reimbursement issues, and implementation of the Affordable Care Act. [Full Bio]
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