340B Patient Definition Guidelines: How to be Compliant While Meeting Your Patients’ Needs
Since 1996, the Health Resources and Services Administration (“HRSA”) has used one set of standards to describe the factors that determine when a 340B drug may be dispensed to an individual patient, otherwise known as the “Patient Definition Guidelines.”
The one-size-fits-all Guidelines apply to the diverse range of 340B covered entities, but each grant program is likely to have very different relationships with the persons they serve. Federally Qualified Health Centers (FQHCs), Ryan White HIV/AIDS Program grantees, and others have very specific grant requirements that affect their 340B program. The Patient Definition Guidelines can be difficult to apply in the context of new treatment standards, including telemedicine, specialist referrals, and the development of medical homes and medical case management. Patient ineligibility and 340B drug diversion continue to account for a significant number of 340B audit findings, especially in contract pharmacies.
This focused four-hour training has been developed specifically to target the ins and outs of the Patient Definition Guidelines, including how to address the many “gray areas” that covered entities may encounter. Designed for both 340B “rookies” and “vets,” the training will cover these topics and more:
- Critical elements of the Patient Definition Guidelines
- Relationship between grant requirements and the Patient Definition Guidelines
- The gray areas, such as telemedicine, clinic administered drugs, and patient referrals, and how to address each to maintain compliance
- Documenting patient eligibility – before and after an audit
- Patient eligibility issues in 340B contract pharmacy arrangements
- Avoiding “too good to be true” deals and other pitfalls
- Detecting and addressing instances of non-compliance
THE ON-DEMAND VERSION OF THIS TRAINING WILL BE AVAILABLE FOR PURCHASE AFTER THE CONCLUSION OF THE LIVE TRAINING.
- 340B Covered Entity Executive Staff
- Financial Leadership
- Pharmacy and 340B Staff
- Legal and Compliance Teams
After this training, you will be able to:
- Understand the basics of the Patient Definition Guidelines and how to document compliance
- Apply the Guidelines in gray or rapidly developing areas
- Identify and avoid risky arrangements
FTLF Virtual Classroom
Tuesday, April 13, 2021
12:00 pm - 4:00 pm ET
12:00 pm - 12:15 pm
Introductions and Agenda Setting
12:15 pm - 1:30 pm
Elements of the Patient Definition Guidelines
1:30 pm - 2:00 pm
Gray Areas and Emerging Treatment Methods
2:00 pm - 2:15 pm
2:15 pm - 3:15 pm
Importance of Compliance – Audits, Self-Disclosures, and Recordkeeping
3:15 pm - 3:45 pm
Risk Areas – Contract Pharmacies and Problematic Arrangements
3:45 pm - 4:00 pm
General Q&A and Wrap Up
FTLF'S VIRTUAL CLASSROOM
This live, interactive training will take place in FTLF's Virtual Classroom, hosted by Zoom. Should you have any technical questions or would like more information, please contact us at firstname.lastname@example.org or 1-855-200-3822.
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]
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 4.5 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, and Legal/Compliance Teams
- Advanced Preparation: None
- Program Level: All
- Delivery Method: Group Internet Based
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).
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