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340B Insight provides members and supporters of 340B Health with timely updates and discussions about the 340B drug pricing program. The podcast helps listeners stay current with and learn more about 340B to help them serve their patients and communities and remain compliant. We publish new episodes twice a month, with news reports and in-depth interviews with leading health care practitioners, policy and legal experts, public policymakers, and our expert staff.
Narration (00:04)
Welcome to 340B Insight from 340B Health.
David Glendinning (00:12)
Hello from Washington, D.C., and welcome back to 340B Insight, the premiere podcast about the 340B drug pricing program. I'm your host, David Glendinning, with 340B Health. Our guest for this episode is Kevin Forbush, the 340B program director at Intermountain Health. Self-auditing is a critical part of maintaining 340B compliance, but it also can be an important tool for improving the efficiency and effectiveness of
David Glendinning (00:40)
Of hospital 340B operations. We spoke with Kevin about best practices in the self-auditing area. But before we get to that interview, let's do a quick recap of some of the latest news about 340B.
David Glendinning (01:01)
The Health Resources and Services Administration recently announced its approval of drug company plans for the new 340B rebate program that will take effect on January 1st, 2027. The announcement identifies the drugs that will be subject to rebates and provides new details about how the program will operate. The rebate program will apply to certain drugs that also are subject to Medicare's drug price negotiation program. Instead of receiving their 340B discounts at the time of purchase,
David Glendinning (01:31)
Hospitals and other covered entities will pay higher prices up front and then submit claims data to obtain rebates from drug companies. The approved plans establish requirements for submitting rebate claims, including the information hospitals must provide and the processes drug companies will use to review submissions and issue rebates. The announcement marks a significant milestone in the implementation of a program that will change how hospitals purchase affected 340B drugs.
David Glendinning (02:01)
And receive their discounts. Although the initial program covers a limited group of medications, HERSA could expand the rebate model to additional drugs in the future. 340B Health continues to oppose the rebate model because of concerns about its financial and administrative effects on hospitals, including potential delays or denials of discounts. There is much more to know about the approved rebate plans and what hospitals should be doing to prepare. For our 340B Health members,
David Glendinning (02:30)
We've included a link in the show notes to our full analysis of the announcement, including details on the affected drugs, submission requirements, and other important considerations.
David Glendinning (02:48)
And now for our conversation with Kevin Forbush with Intermountain Health. Kevin recently presented at the 340B Coalition Summer Conference on how hospitals can build stronger 340B programs through self-auditing. While he was there, we sat down with him to discuss how to match auditing activities to specific risks, the importance of standardizing processes and documenting findings, and how 340B teams can use data to identify problems and address their underlying causes.
David Glendinning (03:17)
Here's that conversation.
David Glendinning (03:19)
I am here with Kevin Forbush, who is 340B Program Director at Intermountain Health. Kevin is joining us during the ice cream social here at the 340B Coalition Summer Conference. So he gets extra credit for showing up here instead of going to that. Kevin, welcome to 340B Insight.
Kevin Forbush (03:37)
Thank you, David. Nice to be here.
David Glendinning (03:39)
Your pre-conference workshop at the summer conference here was about self-auditing, certainly a hot topic in 340B and one that we have covered in the past and looking forward to speaking about that. First, please tell us a bit about Intermountain Health and the patients and communities you serve.
Kevin Forbush (03:57)
Intermountain Health is an integrated health system serving communities across the Intermountain West with a mission to help patients live the healthiest lives possible. We are a diverse mix of 33 hospitals, including 20 hospital-covered entities and two grantee-covered entities. So our 340B team is a centralized team of experts supporting this large and growing enterprise.
Kevin Forbush (04:22)
We feel like our strong compliance program helps ensure we use 340B savings to support the program's intent and our mission in many ways, primarily through our generous patient financial assistance programs and support of important services that would otherwise not be sustainable. So a specific example that we're proud of are our outpatient infusion services provided in all of our hospitals, including in the most rural of areas.
Kevin Forbush (04:50)
This allows patients to receive cancer and other chronic disease care close to home, saving them hours of travel to larger facilities.
David Glendinning (05:02)
Excellent. And many people when they hear self-auditing, they're probably gonna think maybe only about compliance, but I understand your workshop was really about building a strong 340B program more broadly. So wh why did you describe it that way?
Kevin Forbush (05:20)
Self-auditing is really another way of talking about optimizing processes in general. The same concepts apply across almost every operational area in pharmacy and beyond. So when we are developing our tasks, we first ask ourselves, why are we doing this? And what are we tracking? Who owns the work and when or how frequently should it happen?
Kevin Forbush (05:46)
And the goal is to build systems that work consistently rather than relying on individual expertise.
David Glendinning (05:53)
Makes sense to me.
David Glendinning (05:54)
Me?
David Glendinning (05:55)
And one of your key themes also from looking at your presentation is I thought it was really interesting, just matching the cadence of reviews to the actual risk, which I hadn't really seen that concept written out before. How how do you think three forty B organizations or organizations in general should think about that concept?
Kevin Forbush (06:16)
We really want the people who are doing the work to stay engaged and not feel like it's busy work. So not every activity needs the same frequency. And so for us, usually the frequency of work matches the the refreshing of new data. And every task should map to an specific compliance or operational risk. So that avoidance of creating unnecessary work simply because
Kevin Forbush (06:44)
that's how it's always been done, just doesn't feel right. So for us, the right cadence balances risk, workload, and our available resources.
David Glendinning (06:54)
So when you joined Inter Mountain's compliance program, what what sort of stood out for you at that point? What did you see as the biggest I would say opportunities for change in this area?
Kevin Forbush (07:07)
I was walking into a very good situation and we had a software-based compliance task calendar and that really helped lay the groundwork for us to organize our work. But one of the things I had taken from my previous roles was the importance of documenting the work and documenting the processes and documenting follow-ups so they're they don't get lost in the
Kevin Forbush (07:37)
The work of the day. So we realized that, you know, consistency through these documented processes was just as important as completing the processes itself. So not long after my arrival, we emerged with another health system, which added a layer of complexity.
Kevin Forbush (07:57)
But also a great opportunity for us to take the best of both programs, find ways to standardize and scale it across this much larger organization. And that really has become essential for bringing everything and everyone together.
David Glendinning (08:14)
So a merger pretty soon after you showed up, that seemed like a a real test of of all of those concepts. So glad you're glad you're through it. So when you're talking about this concept of standardization, having a a compliance program that is standardized that you can then scale. What does that look like in practice?
Kevin Forbush (08:37)
So first it really starts with documenting standard operating procedures. And that creates an anchor for us to develop common work templates and you know some automation tools to help optimize and make our work more efficient. One of the things that we do is we have standardized responses instead of freeform reporting. This allows us for high level monitoring and creation of dashboards to track trends over time. This helps
Kevin Forbush (09:07)
us identify root causes instead of solving the same problem multiple times. We have clearly documented expectations of who's doing what and when. And because we have this standardization, it makes cross coverage a lot easier and it allows programs to grow or shrink without losing consistency. And so this ability to have cross coverage is a huge team satisfier as we're able to take leaves
Kevin Forbush (09:36)
Or extended time off with a clear conscience.
David Glendinning (09:39)
Yes, we all need all need our vacations from time to time, certainly. And sounds like you're building in for that. So I know that your presentation spoke a little bit more about those dashboards that you mentioned and specifically looking for w what you call hotspots. So what are these hotspots? What are things that you're generally watching for in the in the self auditing area?
Kevin Forbush (10:00)
It's about trends rather than chasing down indiv individual or isolated findings. So what we really look for is sudden changes in purchasing or dispensing volumes or unexpected shifts in how claims are accumulating. These trends can be symptoms of larger interface or data submission issues, or it could be a good time to look at our qualification settings. So again, we're trying to look for one root cause instead of having
Kevin Forbush (10:30)
the same team member fixed the same problem multiple times, or worse yet, multiple team members fixing the same problem.
David Glendinning (10:38)
You had mentioned that part of the cadence does involve monthly review. And I imagine some problems can wait until that monthly review, but I suspect others might require some more immediate attention. So how do you think 340B teams should think about the concept of escalation when one of those pops up?
Kevin Forbush (10:59)
We certainly want our frontline staff to feel empowered and well trained to resolve routine issues whenever possible. But that comes with the responsibilities to loop back with the larger group, to share their learnings, and again try to address problems at their root. But the the team is also coached to escalate findings that could be symptomatic across multiple sites or multiple systems. So everyone should know what they own, what they should be reporting.
Kevin Forbush (11:29)
when leaders need to be looped in before a next scheduled escalation meeting. And as a leader, each and every time we should be thanking our frontline staff, even if the problem doesn't check out, to maintain that level of engagement and really create a safe zone for reporting potential issues.
David Glendinning (11:50)
I get the sense that your team really seems to place a lot of emphasis on documenting all of these findings, you know, whether they are potentially routine or more critical i in a consistent way and an understandable way. Why is that so important?
Kevin Forbush (12:05)
So standardized notes make trends much more easy to identify. Consistent reporting improves our dashboard quality. And so when we have these trends, we develop action items that include a responsible owner, what the required action is, and a timeline for completion. So when we're reviewing these potential issues, when we see frequent use of other failure category, that signals.
Kevin Forbush (12:34)
Perhaps it's time to create a new reporting category to to capture all those others under one umbrella. You know, we think better documentation leads to b better decision making over time and it creates a documentation of previous decisions made when in response to what.
David Glendinning (12:54)
Yeah, I got a chance to look a little bit at some of the imagery you had with your presentation of some of the pull down menus, and it really did seem very intuitive in a lot of ways to be able to to point out potential problem areas for the rest of the team. Of course, you know, internal audits are not the only thing, only type of auditing that a 340B hospital or health system might go through. so how do these internal reviews potentially help prepare organizations like yours for external audits?
Kevin Forbush (13:23)
Our software does a great job of capturing our documentation throughout the year and it allows us to just pull previous documentation rather than scrambling before any type of audit, be it an annual external audit or or a HERSA audit. It demonstrates that compliance activities are consistent and they're ongoing. It shows when issues were identified, tracked, and resolved. It gives external auditors confidence in the organization's internal controls. And for our external audits, it helps.
Kevin Forbush (13:52)
The auditors focus attention on areas that truly warrant a closer look.
David Glendinning (13:57)
As the attendees during the pre-conference workshop left that event, what what do you hope the biggest lessons were that they took home with them to be able to strengthen their own three forty B programs at home, whether they're self-auditing or otherwise?
Kevin Forbush (14:14)
I think every task should have a clear purpose tied to a risk. Additionally, if you can't track it, you can't manage it. If you can't standardize it, you can't scale it. If you don't assign ownership, it's likely not going to get done reliably. So building systems so teams can spend less time on managing tasks and more time improving programs and processes. Self-auditing is not a just about finding problems.
Kevin Forbush (14:43)
It's about creating stronger, more sustainable three forty B program operations.
David Glendinning (14:49)
Okay, so if you can't track it, you can't manage it, can't standardize it, you can't scale it, and if you don't assign ownership, it won't get done. I feel like you need to put that frame it maybe and put it up in a few places in the office. I think that's really great.
Kevin Forbush (15:02)
That sounds great.
David Glendinning (15:04)
Well,thank you, Kevin, again for making a beeline right past the ice cream social to come talk to us about self-auditing. Certainly this is not the first time we've spoken on the program about self-auditing. I know it won't be the last because it is such an important topic, but brought some really interesting perspective to it and I know our listeners will appreciate it. So thank you again for being here.
Kevin Forbush (15:24)
All right, thank you, David.
David Glendinning (15:27)
Our thanks again to Kevin Forbush for joining us. His experiences at Intermountain Health demonstrate that effective self-auditing involves much more than checking for compliance problems. By standardizing processes, documenting findings, and focusing on the risks that matter most, hospitals can build stronger, more efficient 340B programs that are better equipped to support their patients and communities. We will be back in a few weeks with our next episode. In the meantime, as always.
David Glendinning (15:56)
Thanks for listening and be well.
Narration (16:01)
Thanks for listening to 340B Insight. Subscribe and rate us on Apple Podcasts, Google Play, Spotify, wherever you listen to podcasts. For more information, visit our website at 340bpodcast.org. You can also follow us on Twitter at 340B Health and submit a question or idea to the show by emailing us at podcast@340bhealth.org.