1. Pharmacy Access Office Hours
April 18, 2019
Focus Topic:
Clinic-Administered Drugs
This session is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) as part of an award totaling $6,375,000. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov.

2. Webinar Logistics We strongly recommend calling in on your telephone
Access Code: #
Your Attendee ID: Listed below the access code in the box under “Select Audio Connection”.
To ask/ answer a question, or share a comments, please use the Chat box on the right hand side of the screen
You can download these slides on Noddlepod, & from NACHC’s NEW 340B/ Rx webpage:
Or go to NACHC.org and search 340B

3. Operational Updates
Focus Topic – Clinic-Administered Drugs
Q&A –
And Comment Box discussions throughout…

4. National Association of Community Health Centers
OPERATIONAL UPDATES
Colleen Meiman
Senior Policy Advisor
National Association of Community Health Centers

5. Additional Support for Rx Operations
Tim Mallett from 340Basics is now under contract with NACHC to provide Training and Technical Assistance (T&TA) to health centers on pharmacy operations.
Contract is funded through BPHC Cooperative Agreement, so:
Thank you BPHC!
Focus is operations, not advocacy.
To access Tim’s expertise, you can either:
Colleen at or
Tim directly at and cc Colleen (This is probably the faster route….)

6. Discriminatory Contracting
Health Centers – and other 340B providers -- are continuing to receive contract addendums from third-party groups offering reimbursement/ fee structures that are inconsistent with Congressional intent.
Because this topic relates to advocacy, we cannot discuss it in this forum.

7. Are You on “Noddlepod”?
An on-line platform, limited to members of the health center “family”, to discuss pharmacy and 340B-related issues.
Free & open to all health centers -- but as it’s not sponsored by BPHC, won’t go into details now.
Do NOT discuss confidential details of reimbursement, etc.
Sign up to join by ing or
It’s actually noDDlepod, not nOOdlepod – but I still thought the image might help.

8. Outreach from “DecisionPoint Research?
DecisionPoint Research (DPR), an independent market research firm, has been hired by a major retail pharmacy chain to study FQHCs’ in-house pharmacies. 
If you or your colleagues are contacted by DPR, please contact Colleen Meiman at before responding.

9. For more info, contact Gavin Magaha at Apexus -
Info on Medicaid & 340B
For more info, contact Gavin Magaha at Apexus -

10. The Ceiling Price Database is LIVE!
Starting this month, 340B providers can verify that they are not being overcharged for 340B drugs.*
Info is available in a new section of the Office of Pharmacy Affairs Info System (OPAIS.)
* Remember that the 340B CEILING price is not always the same as the 340B PURCHASE price, since the PURCHASE price may contain “sub-ceiling” discounts & distributor fees.

11. Are You Overpaying for Vaccines or IUDs?
Neither vaccines nor IUDs are subject to mandatory discounts 340B.
BUT… as a 340B provider, you are eligible for discounts on vaccines, and $50 IUDs (similar to Mirena.)
For info on discounted vaccines, contact Apexus at BPVP or
For info on $50 IUDs, contact or go

12. Miscellaneous
Recordings of most Rx Office Hours sessions are now available on the NEW NACHC Pharmacy website.
A couple months are missing due to Colleen’s IT learning curve….
GAO now conducting a study of methods to avoid duplicate discounts.
Increased focus on contract pharmacy compliance.
If you are contacted by Kalderos, we advise you to respond promptly.

13. Upcoming Office Hours Topics
Looking Ahead
Upcoming Office Hours Topics
MAY: Clinical Pharmacy 101 (Matt Bertsch)
JUNE: TPAs? (Jim Donnelly) or Recent Trends in Audit Findings (Matt Atkins)
JULY: Pharmacy Charges - Sliding Fee Scale & Other Considerations

14. More Learning Opportunities
For people new to 340B:
A “340B 101” webinar – in May (exact date TBD)
340B University for FQHCs – Aug 17 in Chicago (right before NACHC CHI)
For people who work with 340B or their FQHC’s finances:
340B Coalition Conference
July in Washington DC
Three sessions focused specifically in FQHCs
Two will focus on “Three Strategies to Optimize the value of your 340B program.”

15. Summary of Operational Updates
Tim Mallett at for support with operational issues. (Please cc
Sign up for Noddlepod by ing or
Contact Colleen if you are contacted by DecisionPoint Research.
The Apexus website has info about Medicaid and 340B in each state.
FQHCs can purchase discounted vaccines and $50 IUDs.
There are several upcoming learning opportunities around 340B, geared both to “newbies” and “old hands.”

16. Please do the 1-minute evaluation

17. Focus Topic: Clinic-Administered Drugs
Speaker: Rebecca (Becky) Cheek PharmD., BCACP
Chief Pharmacy Officer-Grace Health
340b Auditor/Consultant-Cheek Consulting, PLLC

18. 340b-Clinic Administered Drugs
Rebecca Cheek, PharmD., BCACP
Chief Pharmacy Officer-Grace Health
340b auditor/consultant-Cheek consulting, pllc 18

19. Today’s Agenda Purchasing clinic administered drugs
Auditing clinic administered drugs

20. Grace Health Grace Health is an FQHC in southeastern Kentucky
7 clinics, 39 school based health sites
Has acquired 2 primary care offices over the last five years
The mission of Grace Health is to show the love and share the truth of Jesus Christ to southeastern Kentucky, through access to compassionate, high quality, primary health care for the whole person.

21. Clinic Administered Drugs
What data does OPA ask for pertaining to clinic administered drugs in an audit?
A listing of locations where health care services are provided to individuals for which the clinic deems itself responsible for the health care services provided for purposes of meeting 340B eligibility
Provide a “universe” of all 340B drug orders and administrations provided to patients from the parent site, offsite facilities/child sites, and pharmacies.
Clinic administered drugs are a “universe”.

22. Carve-in vs Carve-out
CHC’s must decide if they will carve-in or carve-out when registering a site on OPA.
“Will you bill Medicaid for 340b drugs?”-question on OPA site pertains to clinic medications and not pharmacy.
Carve in-340b drugs are purchased on 340b and billed to Medicaid
Carve out-340b drugs are not billed to Medicaid 22

23. Carve-in
You have decided to carve-in and you registered your Medicaid billing NPI and Medicaid number on the OPA site and they are also on the Medicaid Exclusion File. What do you do now?
Determine the drugs that you are going to use in the clinic.
Which of those drugs are going to be billed to Medicaid? In other words, which drugs have a j-code? Or will you purchase all drugs on 340b?
How will you track the 340b drugs?
How will you audit the 340b inventory processes? 23

24. Drug Purchasing
Grace Health has two purchasing accounts for each site. One is 340b and one is retail.
I purchase all of the billable drugs (drugs with j-codes) on the 340b account. Ex: Ketorolac-J1885, Ceftriaxone-J0696
I purchase the rest on the retail account. Ex: Tylenol, ibuprofen, clonidine tabs, etc.
I have found this is the simplest way to purchase and track clinic administered drugs but there are other ways.
Ex: Purchase all on 340b and attach a code to the drugs with no j-code to track? 24

25. Drug Administration
How do you track the clinic administered drugs that are given in the clinic?
Log
Very time consuming
Must document all drugs coming in and going out
Sometimes only option
EMR report
Only as good as the data entered into EMR
Be aware of billing errors 25

26. 340b Drug Log Date Invoice # Quantity received Drug admin.
Quantity/ dose
Patient/ DOB
Prescriber
Total 26

27. Electronic Medical Records report
Includes:
Date
Patient/DOB
Drug/NDC
Quantity/dose given
J-code
Prescriber 27

28. Auditing clinic administered drugs
Prepare the data needed to audit
Purchasing records/invoices
Log/EMR report
Auditing forms
Do an actual physical inventory 28

29. Auditing clinic administered drugs
Balance on-hand+purchases- administrations/outdates/returns/recalls/waste=Current balance on- hand.
Compare purchases and administrations for the designated time period audited and determine reasonable percentage. 29

30. Auditing forms (1) 340B drug name and strength (2) NDC
(if virtual inventory)
(3)
Billing unit per package (if virtual inventory)
(4)
Date range selected through today’s date
(5)
Beginning inventory
(units)
(6)
(–) Dispensed
(7)
(+) Purchased
(8)
(=)
Ending
inventory
(9)
Inventory Units Reconciled?
(10)
Variance Resolved?
Yes No 30
Table 2
Purchases and Dispensations Reconciliation Table
Time period tested: begin date_____ to end date_____.
(Attach data to substantiate reconciliation for each sample)

31. Clinic administered drugs
Compliance is a continuous process and is the responsibility of the covered entity.
Purchase drugs
Administer drugs
Audit drugs 31

32. Issues
Must include inventory process from ordering to compliance auditing in your policies and procedures and follow them.
New clinic sites and eligibility.
Acquired physician offices and eligibility.
Billing errors.
Medication documentation 32

33. Additional Questions? Rebecca Cheek, PharmD., BCACP
Chief Pharmacy Officer
Grace Health
1019 Cumberland Falls Hwy.
Corbin, KY 40701

34. Please do the 1-minute evaluation

35. General Q&A Reminder: Qs submitted in advance get priority.

36. Applying Sliding Fee Scale to Rx
Per HRSA/BPHC, SFDS requirements apply to the “service” part of the costs associated with providing a drug – namely, the dispensing costs.
BPHC does not explicitly require FQHCs to apply the SFDS to the cost of the drugs themselves (called the “ingredient cost”), as they are considered supplies rather than services.
It does allow the ingredient cost to be discounted.
It’s important to make a distinction* between:
Dispensing Cost – must follow SDFS rules
Ingredient Cost – SDFS requirements do not apply
See Manual excerpt (on NACHC webpage) for more info on setting charges for drugs
*This distinction must officially exist for SFS drugs, even if no such distinction exists for drugs for which reimbursement is available.

37. Other Questions?

38. Please do the 1-minute evaluation