340B Contract Pharmacy & TPA Arrangements
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;
- Developing sliding fee discount scales that comply with HRSA requirements;
- Protecting yourself against discriminatory reimbursement contracts;
- 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
*Please Note: This training is limited to covered entities. If you are not a covered entity and would like to register for this training, please contact us
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
- Review and improve existing policies and procedures to reduce 340B audit risks
Wednesday, March 11, 2020
9:00 am - 5:00 pm
|8:30 am - 9:00 am||Continental Breakfast|
|9:00 am - 9:15 am||Introductions and Icebreaker|
|9:15 am - 10:15 am|
Diversion and Duplicate Discounts
|10:15 am - 10:30 am||Break|
|10:30 am - 12:00 pm|
340B and Medicaid Reimbursement
|12:00 pm - 1:15 pm|
|1:15 pm - 2:00 pm|
What to Know Before Signing a Vendor Agreement
|2:00 pm - 2:45 pm|
Monitoring and Oversight of Vendors
|2:45 pm - 3:00 pm||Break|
|3:00 pm - 3:45 pm||"Too Good to Be True" Proposals|
|3:45 pm - 5:00 pm|
Case Studies on Day 1 Material
Discussion RE: Implementing an Audit Protocol
Thursday, March 12, 2020
9:00 am - 12:30 pm
|8:30 am - 9:00 am|
|9:00 am - 10:30 am|
What can go wrong?
Material Breach and Self-Disclosure
|10:30 am - 10:45 am|
|10:45 am - 11:30 am|
Vendor Disputes Related to 340B Liability
|11:30 am - 12:15 pm||Case Study on Day 2 Material|
|12:15 pm - 12:30 pm||Training Wrap-Up|
Hyatt Place Washington DC/Georgetown/West End
Kimpton Hotel Palomar DC
The St. Gregory Hotel - Dupont Circle
Kimpton Hotel Madera
The Embassy Row Hotel
The Dupont Circle Hotel
Hilton Garden Inn - Washington DC/Georgetown Area
Embassy Suites - Georgetown
A Partner with the firm, Mike practices in the Federal Grants and Health Law groups, and has over three decades of experience advising community-based organizations on a broad range of legal matters. Specifically, he offers guidance to Federally Qualified Health Centers, other federal grantees, and several professional and trade associations on the 340B drug discount program, tax exemption, grants law, and fraud matters. [Full Bio]
As of June 2023, Jason Reddish is no longer with the firm.
Jason focuses his practice on the federal 340B drug discount program and the complex legal and compliance issues facing safety net providers, pharmacies, and other 340B program stakeholders. Jason began his career representing pharmaceutical manufacturers before finding his passion helping 340B program covered entities, including disproportionate share hospitals, Federally Qualified Health Centers, Ryan White HIV/AIDS clinics, and other grantees navigate the 340B program. [Full Bio]
Participants can earn up to 11.40 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.
- Prerequisites: None
- Target Audience: 340B Covered Entity Executive Staff, Financial Leadership, Pharmacy/340B Staff, Legal/Compliance Teams
- Advanced Preparation: None
- Program Level: All
- Delivery Method: Group-Live
Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).
- 9.50 Certificate of Attendance
Please Note: This training is limited to covered entities. If you are not a covered entity and would like to register for this training, please contact us
Each registration must be in the name of the individual(s) who will attend. This allows FTLF to communicate important course information to the actual attendee(s), add training materials and handouts to the right account, and properly assign certificates of attendance or CPE credits.
To register for this training:
- For yourself: login to your account and register with your personal information
- For someone else: login with the ATTENDEE’S login information or create an account for the ATTENDEE and register from the ATTENDEE's account
- For a group: email Learning@ftlf.com to complete group registration
If you encounter problems or have questions Contact us.
We accept payment by PayPal, credit card, and check. Payment for any live training is due upon registration. If payment is not received in full prior to the start of the event, FTLF reserves the right to cancel your order and deny you entrance to the training.
All cancellation or transfer requests must be received in writing at firstname.lastname@example.org. Requests for refunds or transfers for in-person events will be granted according to the following schedule:
- 30 or more days prior to the event, requests for a full refund or a transfer without a fee will be granted.
- Between 11 to 29 days prior to the event, requests for cancellations will be granted a 50% refund and requests for transfers will be granted, space permitting and subject to a transfer fee.
- Within 10 days of the event start date, no requests for refunds or credits will be granted. At FTLF's discretion, late transfers may be granted, space permitting and subject to a transfer fee.
If there are extenuating circumstances regarding your cancellation, please reach out to the FTLF Training Team directly at email@example.com.