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(pleasant music)

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- Welcome to "340B
Insight" from 340B Health.

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- Hello from Washington DC,

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and welcome back to "340B Insight,"

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the podcast about the
340B drug pricing program.

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I'm your host, David
Glendinning with 340B Health.

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Our guest for this
episode is Melissa Bruce

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with UNC Health based in North Carolina.

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On the show, we recently covered

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the topic of navigating 340B audits

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with one of the presenters

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at the most recent 340B
Coalition Conference.

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We also wanted to speak with a 340B expert

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on how hospitals can help prevent findings

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for one of the key compliance violations

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that auditors look for,
duplicate discounts.

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And that's where Melissa came in.

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But first, let's take a minute

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to cover some of the
latest news about 340B.

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(exciting music)

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There is new federal legislation to end

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drug company restrictions on access

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to 340B pricing through
contract pharmacies.

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Congresswoman Doris Matsui,

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a democrat from California

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recently introduced the
340B PATIENTS Act of 2024.

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It would clarify the 340B
statute to bar drug makers

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from imposing restrictions

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or conditions on covered entities

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receiving 340B discounted drugs,

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regardless of where
those drugs are dispensed

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to the entity's patients.

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If the bill were to become law,

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it would end the restrictive policies

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from the more than 30 drug companies

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that now have them in place.

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Visit the show notes

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to read Congresswoman
Matsui's announcement

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and 340B Health's statement
on the legislation.

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State governments also
continue to make progress

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on the contract pharmacy dispute.

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In one of the most recent developments,

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a federal appeals court has cited

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with Arkansas health officials

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regarding a law preventing restrictions

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on 340B contract pharmacies in that state.

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The pharmaceutical
industry had sued the state

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over the constitutionality of the law,

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but the court issued a
decision, saying that

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federal statute does not
preempt state law in this case.

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340B Health members can
read more about the decision

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and possible next steps in the court case

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by visiting the show notes.

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(exciting music)

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And now, for our feature
interview with Melissa Bruce.

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Melissa is a 340B certified
compliance analyst

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for UNC Health.

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She presented on a panel

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at the 340B Coalition Winter Conference

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about duplicate discount prevention.

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This is one of the most
important compliance requirements

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for 340B hospitals, and
it can be quite complex.

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But UNC Health has been
pursuing an innovative approach

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to duplicate discount prevention,

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and we spoke with Melissa
about some of the lessons

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the health system has learned
during implementation.

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Here's that conversation.

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- I am speaking with Melissa Bruce

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(atmosphere humming)
(people chattering distantly)

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here at the 340B Coalition
Winter Conference,

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and we are competing with
the Ice Cream Social.

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So, we're gonna try to keep our mind

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on what we're here to talk about today,

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and that is duplicate discounts.

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So Melissa, welcome to "340B Insight,"

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thank you for being here.

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- Yeah! Thanks David,
thanks for having me.

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- Tell us a little bit if
you could, about UNC Health

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and the patients you serve there.

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- Sure!

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So, UMC Health is
comprised of 14 hospitals

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in over 700 clinics.

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The 340B program management team,

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that's who I'm a part of,

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oversees the program compliance
for 10 covered entities.

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And we service all of North Carolina.

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And kind of your basic
patient mission for us

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is going to be improving the health

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and wellbeing of North Carolinians
and others whom we serve.

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- Wonderful.

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Well, we've had episodes before

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where we've focused on 340B
audits, but we have not yet

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done a deep dive on one very
important element of that,

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which is preventing duplicate discounts.

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So, to start with,

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what do we mean when we talk
about duplicate discounts?

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- So, a duplicate discount

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is really when you have

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drug coverage that can
involve Medicaid rebates

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that are paid out to
states from manufacturers,

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as well as providing the 340B
discount to covered entities.

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When we talk about duplicate discounts,

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we're looking at making sure

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that the covered entity
has mechanisms in place

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to prevent the duplicate discount

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or the risk of an audit finding.

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So, it's just really
important to keep in mind

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from a covered entity that

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that responsibility lies
within that covered entity,

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and not necessarily with the manufacturer

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or with the state Medicaid agency.

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- Clearly, this is gonna be high

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on the list of compliance
concerns for covered entities,

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and I understand there may
be different factors at play

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based on what state

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a covered entity's operating in, correct?

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- It can vary state by state,

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and it's especially
important to think through,

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if you're a covered entity,

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what are the requirements
in your home state.

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Another piece of that is if you
have multiple border states,

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or if you're in a high
kind of pass through area

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where you have a lot of tourists,

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or maybe a high college
town, where you will see

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a lot of different states.

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And so, it's really taking a
look at how varied they can be,

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what the requirements are,

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and what type of Medicaid is even provided

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within that state.

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Let's say, if it's fee for service

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and you have managed Medicaid,

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how do you want to address those?

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Do you wanna carve in or
do you wanna carve out?

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And really what that means
is if you're going to bill

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fee for service Medicaid,
you're going to carve in

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for your 340B drugs.

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If you decide, hey,
these particular states

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that might be not necessarily
state, you only have one claim

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that you wanna carve out,

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so you're choosing not to
bill Medicaid and 340B drugs.

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We have several states that
are mandatory carve out states,

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meaning that you don't have
the option to bill Medicaid

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and use 340B drugs for those patients.

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And then, on the flip side,
you have a couple states

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that are mandatory carve in.

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And so, that's a whole
different level of complexity

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because then you really have to focus on

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understanding the EHR
and billing requirements,

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and you don't have a choice in the matter.

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So, really understanding where are you at

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for your covered entity,
is at your home state?

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Which is obviously the most important.

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But as well as a border
state, you might have

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half your volume coming at the border,

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and you really need to
be able to understand

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the billing requirements for both sides.

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- Okay, so carving in, carving out,

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fee for service versus managed care,

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there's certainly, adding
a bunch more terminology

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to the list, which is not
uncommon with 340B compliance.

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You mentioned the complexity
level before, how complex

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can this actually get

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for a system like UNC Health?

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In terms of having systems

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in place to prevent duplicate discounts?

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- So, it can get very complex,

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especially when you're looking
at multiple child sites.

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Because each child site needs to have

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consideration for the Medicaid billing.

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So, one big thing that
we need to talk about

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is the Medicaid exclusion file.

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So, this is a requirement
on OPAC for every 340B ID

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within that program structure.

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So if you are a large institution

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and you have multiple child sites,

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that it can vary from two child sites,

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it could be 100 child sites,

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that every one of the child sites

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should be operationalizing Medicaid

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the same from a compliance standpoint.

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If you decide only half
of them are gonna carve in

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and then the other half
are gonna carve out,

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it really is understanding
the compliance risk

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associated with being
able to audit for that,

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and maintaining accuracy on
the Medicaid exclusion file,

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as well as ensuring that
OPAC mirrors the operations

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within those child sites.

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So the complexities for UNCH,

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it really is taking a look
at the cross border areas.

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So, we do have several
that are going to be

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right at the border.

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So, when we talked about understanding

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the different types of Medicaid

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and really understanding
the billing requirements,

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is understanding that those
particular border areas,

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you need to know that patient volume.

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Do you choose to carve
in versus carve out?

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The other side of this
is really understanding

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from a mixed use standpoint,

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so this is the institutional claims

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that are being billed,
not the retail pharmacies,

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how do you manage a carbon carve out list,

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and what does that look like?

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And then, from a retail
pharmacy standpoint,

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it gets a little bit easier

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because you've got your bin and PCN,

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and group lists that you still
have to compile the data,

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but it's a lot more easily identifiable.

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And then if you do have to

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implement a carve out
list, that tends to be

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a little bit on the easier side
versus trying to figure out

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different payers in
the institutional area.

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- When we think about the 340B hospitals

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that 340B health represents, our members,

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we're always on the
lookout for ways to help

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manage some of those types of complexities

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within the program.

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So, what kinds of processes

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can hospitals implement to handle,

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or perhaps reduce these
levels of complexities

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while still remaining
compliant with all 340B rules?

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- So, there's a couple of types of process

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that can be considered.

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So, you have manual workflows,

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and these are really, when
you talk about manual,

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it really is manual.

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It's reviewing Medicaid
dispensations, it's taking a look at

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how do you identify these payers?

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How do you get into your EHR?

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So, it's understanding within the EHR

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or who in the organization
can even help you say, hey,

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this particular payer name
is fee for service Medicaid.

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If you don't know what that looks like

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or even managed care organization,

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sometimes the naming convention

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can look like a commercial payer.

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And really, this is where
you get into collaborating

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within your covered entity,
is bringing out knowledge

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and helping you close the gap.

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Especially when we're
looking at carve out lists,

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preventing those 340B
accumulations is imperative.

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If you do not, and you're carving out

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but the manufacturer
thinks you're carving in,

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this is a duplicate discount.

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And so, you're trying to prevent that,

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and you might need a little
bit of help, and that's okay.

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It really is just honing
in on those experts.

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And then another process
is really taking a look at

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a cadence check.

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So if a weekly check
becomes very cumbersome,

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do you have resources?

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Do you have somebody who is Excel-savvy?

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And if you do and you start
to get heavily Excel-based,

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and this resource is fantastic,

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but they're so great,
they might get promoted.

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And then what do you do?

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And then another kind of option

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which isn't gonna sound too pleasant,

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is carving out entirely.

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From a financial standpoint,

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understandably so, it's likely not viable.

262
00:10:47,400 --> 00:10:50,490
However, if you don't have a resource

263
00:10:50,490 --> 00:10:52,650
to understand EHR configurations,

264
00:10:52,650 --> 00:10:55,800
how do you apply those modifiers,
or how do you go through

265
00:10:55,800 --> 00:10:58,770
applying the 340B actual acquisition cost?

266
00:10:58,770 --> 00:11:00,930
You might need to do a temporary carve out

267
00:11:00,930 --> 00:11:02,550
just until you get that down.

268
00:11:02,550 --> 00:11:05,220
Biggest piece on that to consider is,

269
00:11:05,220 --> 00:11:07,710
while you might be losing
out on 340B savings,

270
00:11:07,710 --> 00:11:09,330
you are considering the compliance

271
00:11:09,330 --> 00:11:10,680
for the entire program.

272
00:11:10,680 --> 00:11:12,840
And so if it's a very
short period of time,

273
00:11:12,840 --> 00:11:14,130
you get somebody in place

274
00:11:14,130 --> 00:11:15,720
and you get those modifiers set,

275
00:11:15,720 --> 00:11:18,660
then you can get right back to carving in.

276
00:11:18,660 --> 00:11:20,340
- I'm getting the feeling here

277
00:11:20,340 --> 00:11:22,620
that there's another option at play,

278
00:11:22,620 --> 00:11:24,540
and certainly based on
your presentation here

279
00:11:24,540 --> 00:11:26,040
at the conference, another option

280
00:11:26,040 --> 00:11:30,420
besides either manual
workflows or total carve out.

281
00:11:30,420 --> 00:11:32,820
So, how did UNC health decide

282
00:11:32,820 --> 00:11:35,130
to approach this complexity challenge?

283
00:11:35,130 --> 00:11:37,890
- Yeah, so we really had to
think outside of the box.

284
00:11:37,890 --> 00:11:40,500
And it was talking through

285
00:11:40,500 --> 00:11:42,660
various resources even within the team

286
00:11:42,660 --> 00:11:45,150
and team's leadership of understanding

287
00:11:45,150 --> 00:11:46,680
what was happening in our TPA,

288
00:11:46,680 --> 00:11:48,750
what was happening in our EHR.

289
00:11:48,750 --> 00:11:52,950
So, our approach was to take
an automated workflow approach,

290
00:11:52,950 --> 00:11:56,190
which is truly just
streamlining those manual tasks.

291
00:11:56,190 --> 00:12:01,190
So, what we did is took a look
at our TPA dispensation file,

292
00:12:01,320 --> 00:12:03,570
and that was really again using resources

293
00:12:03,570 --> 00:12:05,820
within the covered
entity, who is the expert?

294
00:12:05,820 --> 00:12:08,730
Who manages the data that you might need?

295
00:12:08,730 --> 00:12:12,180
And working with our
director of revenue cycle

296
00:12:12,180 --> 00:12:13,560
and identifying payers

297
00:12:13,560 --> 00:12:16,650
that we consider either
out of state Medicaid,

298
00:12:16,650 --> 00:12:19,710
or there's third party billing services.

299
00:12:19,710 --> 00:12:21,990
What shows up on the institutional claim

300
00:12:21,990 --> 00:12:23,700
is not the name of the Medicaid payer,

301
00:12:23,700 --> 00:12:25,200
it's the name of the service.

302
00:12:25,200 --> 00:12:26,550
So, you might look at that

303
00:12:26,550 --> 00:12:28,590
and not think it's
Medicaid, but it really is.

304
00:12:28,590 --> 00:12:31,290
And so, how do you build
this carve out list?

305
00:12:31,290 --> 00:12:32,850
So, we worked really hard

306
00:12:32,850 --> 00:12:35,250
with a few different
groups of people to create

307
00:12:35,250 --> 00:12:36,540
a carve out list,

308
00:12:36,540 --> 00:12:39,900
and then what we did is we
decided we wanted to block

309
00:12:39,900 --> 00:12:43,260
those list of payers
from flowing to the TPA.

310
00:12:43,260 --> 00:12:47,100
So, stopped 340B
accumulations, we were able

311
00:12:47,100 --> 00:12:50,880
to successfully get
through one implementation.

312
00:12:50,880 --> 00:12:52,500
We do have many more to go.

313
00:12:52,500 --> 00:12:55,680
So, just keeping in mind
thinking outside the box,

314
00:12:55,680 --> 00:12:56,910
get the wheels turning,

315
00:12:56,910 --> 00:12:59,670
the size of the covered
entity is super important.

316
00:12:59,670 --> 00:13:03,120
If you have just a small low bed dish

317
00:13:03,120 --> 00:13:05,010
with no child sites,

318
00:13:05,010 --> 00:13:07,710
so using automation if you
don't have the resources

319
00:13:07,710 --> 00:13:09,150
might not be the most appropriate.

320
00:13:09,150 --> 00:13:12,480
But you can look at
automating even an Excel file

321
00:13:12,480 --> 00:13:15,540
if you're doing monthly audits,
or if you're going through

322
00:13:15,540 --> 00:13:17,820
and you're doing them
quarterly, think different ways,

323
00:13:17,820 --> 00:13:20,320
just get outside of the
box, ask other people too.

324
00:13:21,330 --> 00:13:23,610
Big thing is, is using your peers.

325
00:13:23,610 --> 00:13:26,220
Find another covered entity
that's similarly structured,

326
00:13:26,220 --> 00:13:27,810
and ask them what they did.

327
00:13:27,810 --> 00:13:29,760
- That process does sound very compelling.

328
00:13:29,760 --> 00:13:33,090
The automation process for,
as you say, covered entities

329
00:13:33,090 --> 00:13:36,240
for whom it makes sense
to to implement it.

330
00:13:36,240 --> 00:13:39,780
At UNC Health, what benefits did you see

331
00:13:39,780 --> 00:13:42,360
from moving to workflow automation?

332
00:13:42,360 --> 00:13:45,090
- So, the first one is really
taking a look at accuracy

333
00:13:45,090 --> 00:13:46,770
and improving accuracy.

334
00:13:46,770 --> 00:13:48,090
Accuracy is really important

335
00:13:48,090 --> 00:13:51,150
because it instills reliability,

336
00:13:51,150 --> 00:13:53,850
which then really shows your stakeholders

337
00:13:53,850 --> 00:13:57,180
that what you're doing is valid,

338
00:13:57,180 --> 00:13:59,640
and it really increases the
trust they have with you,

339
00:13:59,640 --> 00:14:02,190
especially if you're an
enterprise level team.

340
00:14:02,190 --> 00:14:05,220
If you're doing work on behalf
of a covered entity client,

341
00:14:05,220 --> 00:14:07,200
and letting them know that hey,

342
00:14:07,200 --> 00:14:10,080
what we're doing increases accuracy,

343
00:14:10,080 --> 00:14:11,670
which is gonna lower the risk

344
00:14:11,670 --> 00:14:13,650
for duplicate discount finding.

345
00:14:13,650 --> 00:14:15,000
Part of my preparation

346
00:14:15,000 --> 00:14:19,650
for the presentation was really
looking at HRSA's findings.

347
00:14:19,650 --> 00:14:21,847
What audits they've completed.

348
00:14:21,847 --> 00:14:24,630
And something that I just
put into my presentation,

349
00:14:24,630 --> 00:14:26,130
and wanted to kind of mention here is,

350
00:14:26,130 --> 00:14:30,000
since 2015, it was very consistent trend,

351
00:14:30,000 --> 00:14:34,590
that 15 to 20% of entities
that were audited by HRSA

352
00:14:34,590 --> 00:14:36,450
had duplicate discount findings.

353
00:14:36,450 --> 00:14:38,070
So, really thinking through

354
00:14:38,070 --> 00:14:40,800
how can you prevent
them is super important.

355
00:14:40,800 --> 00:14:43,860
Another benefit was improving workflow.

356
00:14:43,860 --> 00:14:46,500
So, by improving workflow,
you're taking out

357
00:14:46,500 --> 00:14:48,930
any repeated tasks, you're
becoming more efficient,

358
00:14:48,930 --> 00:14:51,690
you're able to have better
use of your resources,

359
00:14:51,690 --> 00:14:53,460
you're really optimizing

360
00:14:53,460 --> 00:14:55,380
so that you can meet the objectives.

361
00:14:55,380 --> 00:14:57,660
And then finally, it's
looking at time constraints,

362
00:14:57,660 --> 00:15:01,440
and finding new ways that
you can use those resources.

363
00:15:01,440 --> 00:15:04,170
So, there might have been a
project that's been pending.

364
00:15:04,170 --> 00:15:05,003
Or something else

365
00:15:05,003 --> 00:15:06,660
that you needed to kind
of bring to the table,

366
00:15:06,660 --> 00:15:08,850
and now you have this freed up resource

367
00:15:08,850 --> 00:15:10,740
to be able to start a new project.

368
00:15:10,740 --> 00:15:12,870
Or maybe there was another
area within the program

369
00:15:12,870 --> 00:15:15,180
that needs more attention.

370
00:15:15,180 --> 00:15:16,650
That's not duplicate discount-related,

371
00:15:16,650 --> 00:15:19,170
but equally important from
a compliance standpoint.

372
00:15:19,170 --> 00:15:21,210
- You mentioned those HRSA audit stats,

373
00:15:21,210 --> 00:15:24,120
which I'm imagining are top of mind

374
00:15:24,120 --> 00:15:25,320
when you're thinking about this.

375
00:15:25,320 --> 00:15:27,690
So, how did you ensure

376
00:15:27,690 --> 00:15:29,610
that the new process you put in place

377
00:15:29,610 --> 00:15:31,890
was going to work as intended?

378
00:15:31,890 --> 00:15:35,337
- So, we really took a look
at who we needed to talk to,

379
00:15:35,337 --> 00:15:37,710
and who was gonna be
the most appropriate to,

380
00:15:37,710 --> 00:15:40,680
from start to finish, be able to implement

381
00:15:40,680 --> 00:15:42,540
and really understand our requests.

382
00:15:42,540 --> 00:15:45,150
So, first and foremost was identifying

383
00:15:45,150 --> 00:15:47,700
the right person who
could update our logic.

384
00:15:47,700 --> 00:15:50,580
And again, it's taking a
look at that list of payers,

385
00:15:50,580 --> 00:15:52,500
so that carve out list,

386
00:15:52,500 --> 00:15:55,860
and then being able to understand
how the logic truly works,

387
00:15:55,860 --> 00:15:59,340
so that we could apply
exclusionary filters.

388
00:15:59,340 --> 00:16:01,470
Another big piece here, which,

389
00:16:01,470 --> 00:16:04,350
it ended up being a vast
majority of the work,

390
00:16:04,350 --> 00:16:08,430
was validating how the
new logic would work

391
00:16:08,430 --> 00:16:09,660
if we implemented it.

392
00:16:09,660 --> 00:16:12,840
So, what we did is we
identified our covered entity

393
00:16:12,840 --> 00:16:15,990
that we wanted to pilot our
automation workflow with,

394
00:16:15,990 --> 00:16:18,180
which just so happened
to have gone through

395
00:16:18,180 --> 00:16:19,560
a recent HRSA audit,

396
00:16:19,560 --> 00:16:22,380
and started with test file information.

397
00:16:22,380 --> 00:16:25,830
So, the prep work that we
used for that HRSA audit,

398
00:16:25,830 --> 00:16:27,540
it was an out-of-state Medicaid audit,

399
00:16:27,540 --> 00:16:31,830
was our kind of test file that we used,

400
00:16:31,830 --> 00:16:35,760
and then we were able to look
at using that date range,

401
00:16:35,760 --> 00:16:37,560
can we update the logic?

402
00:16:37,560 --> 00:16:40,132
Give me what the new version
of the logic would be.

403
00:16:40,132 --> 00:16:40,965
(atmosphere humming)
(people chattering distantly)

404
00:16:40,965 --> 00:16:43,020
So, it's really just baseline testing

405
00:16:43,020 --> 00:16:45,300
and validating, to look at

406
00:16:45,300 --> 00:16:48,720
did the update and the
logic work as intended?

407
00:16:48,720 --> 00:16:52,170
Or were there inadvertent consequences?

408
00:16:52,170 --> 00:16:55,290
Or, was more data removed from that file

409
00:16:55,290 --> 00:16:56,190
that didn't need to be?

410
00:16:56,190 --> 00:16:58,710
So, were some of those carve in payers

411
00:16:58,710 --> 00:17:00,153
that was the data missing?

412
00:17:01,140 --> 00:17:03,840
Or, did some of the
payers still flow through

413
00:17:03,840 --> 00:17:05,730
and we didn't need them to be?

414
00:17:05,730 --> 00:17:08,490
So, really using that
test case to make sure

415
00:17:08,490 --> 00:17:11,520
that everyone understood
how the change in logic

416
00:17:11,520 --> 00:17:14,100
was going to be applied,
and then making sure

417
00:17:14,100 --> 00:17:16,890
that we continue that through go live.

418
00:17:16,890 --> 00:17:18,300
- That's very interesting.

419
00:17:18,300 --> 00:17:19,770
The idea of doing a dry run

420
00:17:19,770 --> 00:17:22,500
with the previously audited site.

421
00:17:22,500 --> 00:17:26,820
Any lessons that you
learned from this process?

422
00:17:26,820 --> 00:17:29,730
- So, I think the biggest
thing that we really picked up

423
00:17:29,730 --> 00:17:31,770
is that larger,

424
00:17:31,770 --> 00:17:34,650
more complex sites

425
00:17:34,650 --> 00:17:38,370
are going to need more validation.

426
00:17:38,370 --> 00:17:40,320
So, we were kind of
filtering through data,

427
00:17:40,320 --> 00:17:43,350
we thought we understood
how the logic worked,

428
00:17:43,350 --> 00:17:46,410
and it ended up being
that we needed more time.

429
00:17:46,410 --> 00:17:48,660
Going through and looking at how secondary

430
00:17:48,660 --> 00:17:51,930
or tertiary Medicaid payers,
if there was some type of payer

431
00:17:51,930 --> 00:17:55,350
reprocessing that was
occurring, how did that look?

432
00:17:55,350 --> 00:17:58,260
So, it really was looking at individually

433
00:17:58,260 --> 00:18:02,130
from a covered entity instead
of doing a mass rollout,

434
00:18:02,130 --> 00:18:04,290
we needed to do one version,

435
00:18:04,290 --> 00:18:07,140
so that we could understand
really what was going to happen.

436
00:18:07,140 --> 00:18:08,880
Another one was really understanding that

437
00:18:08,880 --> 00:18:12,540
there was a need for frequent
checks, especially at Go Live.

438
00:18:12,540 --> 00:18:16,380
How often is data being sent
to our TPA was a big thing

439
00:18:16,380 --> 00:18:18,000
that I don't think we realized

440
00:18:18,000 --> 00:18:20,010
when payer data flowed through, we assumed

441
00:18:20,010 --> 00:18:23,100
it was going at the same time
as our dispensation file,

442
00:18:23,100 --> 00:18:26,100
and it ended up being a
several week lag time.

443
00:18:26,100 --> 00:18:28,710
So, we needed a larger
amount of time in between

444
00:18:28,710 --> 00:18:31,080
doing validation of the live data,

445
00:18:31,080 --> 00:18:33,750
and so we really got
into setting a precedent

446
00:18:33,750 --> 00:18:37,110
for doing regular cadence
checks after Go Live.

447
00:18:37,110 --> 00:18:39,150
And then finally, the biggest thing,

448
00:18:39,150 --> 00:18:42,120
I think two people think through things,

449
00:18:42,120 --> 00:18:44,940
is that it is not a set
it and forget a process.

450
00:18:44,940 --> 00:18:46,170
Maintenance is key.

451
00:18:46,170 --> 00:18:47,370
You wanna continue to check.

452
00:18:47,370 --> 00:18:50,520
So, what if a new payer
is added to the EHR?

453
00:18:50,520 --> 00:18:52,260
What if a new state is billed?

454
00:18:52,260 --> 00:18:55,260
What happens if the state
billing requirements change?

455
00:18:55,260 --> 00:18:59,340
What happens if one of
your border states ends up

456
00:18:59,340 --> 00:19:01,260
contracting with a
completely different state

457
00:19:01,260 --> 00:19:02,250
and you weren't aware of it?

458
00:19:02,250 --> 00:19:04,470
So, you just really have
to continuously check

459
00:19:04,470 --> 00:19:07,260
and do maintenance is super important.

460
00:19:07,260 --> 00:19:09,540
- After seeing this
positive example from you

461
00:19:09,540 --> 00:19:11,220
and hearing your presentation,

462
00:19:11,220 --> 00:19:14,700
let's assume another health
system out there is sold now

463
00:19:14,700 --> 00:19:18,330
on the idea of implementing
workflow automation.

464
00:19:18,330 --> 00:19:21,450
What additional advice
might you have for them?

465
00:19:21,450 --> 00:19:23,010
- One thing I learned
since my first conference,

466
00:19:23,010 --> 00:19:24,600
is that when you talk
to other people here,

467
00:19:24,600 --> 00:19:27,300
it really highlights that you
are not alone. (chuckling)

468
00:19:27,300 --> 00:19:29,430
And you can actually have a
conversation with somebody

469
00:19:29,430 --> 00:19:30,930
and they know what you're talking about.

470
00:19:30,930 --> 00:19:32,790
One of the biggest struggles
I think that we had

471
00:19:32,790 --> 00:19:35,730
was really communicating
clearly and concisely

472
00:19:35,730 --> 00:19:39,390
what we needed in a way that
it was easily translatable

473
00:19:39,390 --> 00:19:41,370
throughout the covered entity.

474
00:19:41,370 --> 00:19:43,740
Words that we might use in the 340B space

475
00:19:43,740 --> 00:19:45,150
we think means one thing

476
00:19:45,150 --> 00:19:48,107
if you're talking to
somebody in revenue cycle,

477
00:19:48,107 --> 00:19:49,192
if you're talking to somebody,

478
00:19:49,192 --> 00:19:51,150
maybe in your IT department,

479
00:19:51,150 --> 00:19:53,040
but it means something
completely different.

480
00:19:53,040 --> 00:19:56,850
So, making sure that you're
standardizing your terminology,

481
00:19:56,850 --> 00:20:00,090
it's clear and concise, but
also setting an expectation,

482
00:20:00,090 --> 00:20:03,120
maybe have them repeat the
ask back to you to make sure

483
00:20:03,120 --> 00:20:06,090
that they truly understood
what you were saying.

484
00:20:06,090 --> 00:20:07,950
Another one is really engaging with peers.

485
00:20:07,950 --> 00:20:09,480
I mentioned this earlier, is reach out

486
00:20:09,480 --> 00:20:13,470
to another organization that's
the same program structure.

487
00:20:13,470 --> 00:20:15,450
If you use a consulting service.

488
00:20:15,450 --> 00:20:17,580
We have 340B experts everywhere.

489
00:20:17,580 --> 00:20:19,278
Reach out to somebody,

490
00:20:19,278 --> 00:20:20,730
it's okay, it's one of those adages,

491
00:20:20,730 --> 00:20:23,550
there's no stupid questions
340B is one of those things,

492
00:20:23,550 --> 00:20:25,170
ask the questions.

493
00:20:25,170 --> 00:20:27,540
And then finally, I think
this is most important,

494
00:20:27,540 --> 00:20:29,910
be patient and stay motivated.

495
00:20:29,910 --> 00:20:31,590
I've been at the forefront of working on

496
00:20:31,590 --> 00:20:32,850
this particular project,

497
00:20:32,850 --> 00:20:35,700
and it took nine months
to get one covered entity,

498
00:20:35,700 --> 00:20:38,010
and you get through month
three or month four,

499
00:20:38,010 --> 00:20:40,800
and really making sure
that you stay motivated,

500
00:20:40,800 --> 00:20:43,050
and really understanding why
you're doing what you're doing,

501
00:20:43,050 --> 00:20:45,240
and that it is super important.

502
00:20:45,240 --> 00:20:47,760
- Melissa, I enjoyed the opportunity

503
00:20:47,760 --> 00:20:49,080
to look more closely

504
00:20:49,080 --> 00:20:53,280
at such an important element
of 340B compliance with us.

505
00:20:53,280 --> 00:20:56,040
So, best of luck with the rolling this out

506
00:20:56,040 --> 00:20:57,840
to additional sites,

507
00:20:57,840 --> 00:21:01,620
and thank you for sharing your
experience and your advice.

508
00:21:01,620 --> 00:21:03,014
- Yeah!

509
00:21:03,014 --> 00:21:03,910
It was great talking,

510
00:21:03,910 --> 00:21:06,023
and I am so glad that you
reached out about the interview!

511
00:21:07,380 --> 00:21:09,120
- Our thanks again to Melissa Bruce

512
00:21:09,120 --> 00:21:10,620
for helping us better understand

513
00:21:10,620 --> 00:21:13,560
the complexities of
duplicate discount prevention

514
00:21:13,560 --> 00:21:16,410
and how 340B hospitals can navigate them.

515
00:21:16,410 --> 00:21:18,720
We also thank her for
sharing her great advice

516
00:21:18,720 --> 00:21:22,650
and lessons learned with her
fellow conference attendees.

517
00:21:22,650 --> 00:21:25,110
And we wholeheartedly agree

518
00:21:25,110 --> 00:21:28,170
that when it comes to 340B
operations and compliance,

519
00:21:28,170 --> 00:21:30,510
there are no stupid questions.

520
00:21:30,510 --> 00:21:32,940
We hope that all of our listeners grant us

521
00:21:32,940 --> 00:21:35,340
the same grace as well.

522
00:21:35,340 --> 00:21:37,890
What questions do you have for us?

523
00:21:37,890 --> 00:21:39,480
We invite you to send them along

524
00:21:39,480 --> 00:21:42,060
so we can plan topics for future episodes.

525
00:21:42,060 --> 00:21:46,980
Please contact us at
podcast at 340bhealth.org.

526
00:21:46,980 --> 00:21:48,870
We will be back in a few weeks.

527
00:21:48,870 --> 00:21:50,850
In the meantime, as always,

528
00:21:50,850 --> 00:21:53,163
thanks for listening, and be well.

529
00:21:54,762 --> 00:21:58,320
(electronic music)

530
00:21:58,320 --> 00:22:00,840
- Thanks for listening to "340B Insight."

531
00:22:00,840 --> 00:22:04,320
Subscribe and rate us on
Apple Podcasts, Google Play,

532
00:22:04,320 --> 00:22:07,380
Spotify, or wherever
you listen to podcasts.

533
00:22:07,380 --> 00:22:08,700
For more information,

534
00:22:08,700 --> 00:22:12,450
visit our website at 340bpodcast.org.

535
00:22:12,450 --> 00:22:15,780
You can also follow us
on Twitter @340BHealth,

536
00:22:15,780 --> 00:22:19,020
and submit a question or idea
to the show by emailing us

537
00:22:19,020 --> 00:22:20,650
at podcast@340Bhealth.org

538
00:22:28,911 --> 00:22:30,050
(exciting music)

539
00:22:30,050 --> 00:22:33,874
(narrator chanting indistinctly)