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This week, we are joined by Bhupinder Kaur, business analyst and 340B coordinator with NorthBay Healthcare Group in California. Bhupinder presented at the 340B Coalition 2021 Winter Conference on data analysis and shares with us important information that 340B professionals need to know about best practices. Before the interview, we highlight a recently published op-ed on the critical role of 340B savings during the height of the COVID-19 pandemic.
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.
Speaker 1 (00:04):
Welcome to 340B Insight from 340B Health.
David Glendinning (00:13):
Hello from Washington DC and welcome back to 340B Insight. The podcast about the 340B drug pricing program. I'm David Glendinning with 340B Health. Our guest today is Bhupinder Carr, a business analyst, and 340B coordinator for North Bay healthcare group in California. Bhupinder is an expert on data analysis and the important role that it plays in 340B. Earlier this year, she presented on the topic at the 340B coalition winter conference in San Diego. We caught up with her right after her presentation to speak a bit more about best practices for analyzing 340B data and the advantages that data analysis can provide for a hospital or health systems, 340B program. But, before we go to that interview, let's take a minute to cover some of the latest news about 340B.
The Cleveland Plain Dealer recently published an opinion piece on 340B written by Dr. Sherry Williams, a pulmonary critical care specialist and past president of the medical staff for the Metro Health system in Cleveland. Dr. Williams is also a member and past chair of the 340B health board of directors. In her op-ed she describes how at the height of the COVID 19 pandemic, 340B served as a lifeline for Ohio hospitals and their patients in 2021, Metro Health received more than 500 patient transfers from critical access hospitals and other rural facilities, that stabilized severely ill patients until they could be transferred to a higher acuity setting.
340B savings played a major role in helping the hospitals achieve this. Such rural facilities rely on 340B to stay in operation and Metro Health relied on 340B to help cover the costs of caring for these patients amid spikes in overtime pay, supply costs, and other fees. Dr. Williams notes that while this was occurring, drug companies were increasingly imposing restrictions on 340B pricing for drugs dispensed to contract pharmacies. She said these actions were, "Cutting strands of the healthcare safety net during a time of unprecedented strain." She concludes the piece by stating, "The problem is getting worse and must stop before the safety net suffers permanent damage." Please visit the show notes to read the op-ed by Dr. Williams and share it with your colleagues. It's a compelling read.
And, now for our feature interview with Bhupinder Carr. Bhupinder was one of the scores of 340B subject matter experts who brought their expertise to the community through the most recent 340B coalition winter conference. Miles Goldman caught up with her just after her presentation to learn more about 340B data analysis. Here's that conversation.
Myles Goldman (03:24):
Thank you, David. I'm joined by Bhupinder Carr, who is with North Bay healthcare group in California. Bhupinder, welcome to 340B Insight.
Bhupinder Carr (03:33):
Thank you for having me.
Myles Goldman (03:36):
And really appreciate you coming because you have just joined us right after your presentation at the conference so you came over here right after the Q and A.
Bhupinder Carr (03:44):
Yes, I did it. It was a good turnout.
Myles Goldman (03:47):
And, we're going to be talking more kind of an expansion upon the conversation that happened in your session on 340B data analysis, a topic that I know matters to a lot of our listeners.
Bhupinder Carr (04:00):
Yes. It's day to day and kind of what the 340B world deals with. So, it's nice to kind of go in detailed and talk about what we all do and get more information out there for everyone.
Miles Goldman (04:13):
Absolutely. What was your professional journey to becoming a 340B data analyst in your current role?
Bhupinder Carr (04:20):
Yeah, I started out in 2012 in the pharmacy world as a volunteer to kind of just see what it was about. I never thought it would become a career, but here we are. I went into initially the buyer role and kind of just expanded and grew up the ladder from there. That's kind of where I was exposed to the 340B initially. Kind of just brought more interest as to how it works. What are the components, what we need to focus on and kind of just grew from there. Work into the contract pharmacy. And, and then I got my MBA and I feel like that's really good to have because we're doing a lot of the analysis and dealing with the data so it's a good backbone to have.
Miles Goldman (05:04):
Well, let's talk more about your day to day. What does a 340B analyst do and what are the types of projects you work on?
Bhupinder Carr (05:12):
Yeah, so a day to day is always very different. You can never have a consistent day. Some of the items that a data analysis will work on includes analysis of the annual quarterly spending. With the 340B savings or the revenue, it's very key to kind of display that information to your C-suite to kind of see the importance of the 340B program. Another thing is kind of just up keeping the 340B program. That includes the policies and procedures, making sure the contracts are valid and up to date, doing the internal audits, doing the fulfillments of commitments with the vendors, including consignment.
And, then TPA upkeeps, you want to make sure that they're up to date that may include any amendments or changes with the locations you have in both contract pharmacy or split billing. And, then the quarter to 340B price file. I think that's kind of overlooked, but it's definitely an important part of the data analysis.
Miles Goldman (06:11):
So, it's certainly a pretty expansive role.
Bhupinder Carr (06:14):
Oh yeah and that doesn't cover majority of it. There's other moving parts that you kind of deal with day to day, just depending on your organization and kind of what is needed from you.
Miles Goldman (06:25):
What would you say are the largest overall challenges with configuring 340B data?
Bhupinder Carr (06:30):
Yeah, I think there's a lot of moving parts, but I think one important detail is kind of working with the TPAs. Every organization has a different TPA and the data set that's compatible with them is always different based off of what you are able to provide. Just kind of working with that and configuring that data to work for both sites, that's always challenging. And, then I think just having your support from your teams, especially the C-suite or different departments, that's always hard because you want the information that you know is there, but it's just getting the access to it. So accessibility is always a difficult part.
Miles Goldman (07:10):
I want to talk more about the auditing and compliance work you do. Are there situations in auditing where necessary data is difficult to obtain or requires multiple steps to accurately distinguish?
Bhupinder Carr (07:22):
Yes. All the time. As you're working with data elements from different TPAs and using what you're able to provide in your organization, there's a lot of V lookup and pivot table usage to get to the outcome that works and is easily displayed for all team members on either side.
Miles Goldman (07:38):
And, how have you overcome those challenges?
Bhupinder Carr (07:41):
You have to work with the different departments and kind of just show your need for that data. I think providing a number value of what your program is capable of or what is contributing towards the organization. I think that helps because it shows the importance of why you need the data and what it's being used for.
Miles Goldman (08:01):
In terms of compliance, do you also work on annual 340B recertification? And, what are the steps involved in that process for you?
Bhupinder Carr (08:10):
Yes, I do conduct the NL 340B recertification for my [inaudible 00:08:15]. I feel like having a universal crosswalk that displays every location with the key components that are needed really helps with this process, goes a lot smoother. Some of the steps that include our verifications of the locations through your cost report. So, you want to check there's revenue expenses listed. You can also check the address as well. I think that's also key, especially with the COVID locations. Some locations have closed down, so they've moved.
And, then also running a contract pharmacy site revenue reporting to kind of remove any non generating locations. You also want to check with your TPAs or your contract pharmacy vendors to see if the location fees are affected when you do that. So, take that into consideration when you're removing non generating sites
Miles Goldman (09:06):
In your presentation, you discussed the 340B financial analysis work you do for your hospital. How does your health system executive leadership use the 340B data you provide to make decisions?
Bhupinder Carr (09:18):
As every healthcare system, numbers go a long way with loss or revenue. So, I feel like having that number for the 340B program overall kind of supports you in any potential changes that you want to make. Changing an NDC or to removing a site location, or adding a site location. If you're able to show the value of that, C-suite is usually there to back you up. So, and then also providing education about what 340B is if you're initially starting up with introductions, that's always a great topic.
Miles Goldman (09:54):
How do you go about educating your colleagues and executive leadership on 340B?
Bhupinder Carr (10:00):
Yeah, so I always usually recommend the 340B university to new hires to kind of just [inaudible 00:10:08] through it to see if they have any questions, what they understand, what they don't understand. And, then I also do a annual 340B competency for team members that are kind of interactive with the 340B program to kind of just keep them up to speed with the changes, make sure they're aware of the changes and kind of know what to do and where to go to find the information.
Miles Goldman (10:29):
So, you make the exam up yourself, you create it?
Bhupinder Carr (10:34):
Yeah, I do make it myself. It is just a few questions, but it mirrors the changes that have recently occurred within our organization or the 340B program itself.
Miles Goldman (10:44):
It's great that you're providing that professional development to your colleagues. What type of financial analysis does your health system leadership request most often?
Bhupinder Carr (10:54):
I think mostly it's a budget analysis. I feel like that's kind of very important, especially with the COVID crisis within every organization. The budget is key to kind of making sure we're in par with that. And, then with the drug spend, you always want to stay below the numbers, but if you are able to show the need for what you have and what you've spent, I think that's always a good backbone to have.
Miles Goldman (11:23):
I imagine there was a lot of moving parts in the financial analysis during COVID with everything going on with the budget?
Bhupinder Carr (11:30):
Oh yeah, of course. Like I said, we had location closures, so that was always a change. And, then the call centers, just moving around up-keeping with that.
Miles Goldman (11:41):
Does your financial analysis support efforts to communicate about how your hospital is using its 340B savings?
Bhupinder Carr (11:49):
Yes. We have a 340B impact profile that we upkeep and we update on annual basis when we do the recertification. And, we use that to present to newcomers, or just if we have someone interested within our organization, we provide that for them. We also have charity cards for our patients that social services use on behalf of the pharmacy department.
Miles Goldman (12:16):
Still thinking about financial analysis, but more of a compliance type question, why is the 340B quarterly price file important to the analysis? Have you found any techniques to use more effectively the OPA 340B pricing database?
Bhupinder Carr (12:34):
Yeah. So, the currently price file update is important because we want to be charging correctly to our patients. We want to charge for what we are actually getting to kind of transfer the 340B savings to them, but it kind of also goes into we want to get paid for what we charged as well, because that price file represents the payers. It is always a difficult process, but working with your wholesaler and your IT team definitely helps. Having that line of communication between both is what's needed and using various programs like Excel or access definitely helps.
Miles Goldman (13:13):
Do you have an example of where you analyzed the data and found a way to make your hospitals program more efficient and then were able to implement it?
Bhupinder Carr (13:21):
We had a contract pharmacy that we initially signed up on and it was a couple of months and there was no movement of the claims. And, so we reached out to the TPA to have them kind of give us an understanding of what's going on. So, they looked into it deeper investigated and found out that the reporting from the contract pharmacy to them was not occurring correctly due to an error. And, so just having any sort of oddball things that you identify in any reports is always good to look into and investigate and analyze and make sure that it makes sense to why that either is zero or a high number or negative number and just kind of follow through with the process.
So, we're still waiting on as to how to complete it or what the complete process is going to be, just because it's been a few months, they need to go back view the data and kind of figure out what's been going on.
Miles Goldman (14:28):
So, it sounds like it's a bit of a lengthy process from when you identify the error to actually making changes?
Bhupinder Carr (14:35):
Yeah. It is definitely lengthy. When you first initially find the problem, you want to run the analysis to where you can support it, figure out what's going on, why you're kind of reaching out to your vendor or TPA. Then you go to your TPA, have them run it based off of their end, do the analysis, figure out what's working for them, what isn't working and then kind of get together and figure out the solution for that. So, it definitely takes time because there's multiple covered entities for every TPA. So, it's always good to reach out and then just keep on it.
Miles Goldman (15:12):
Well, that certainly sounds like important advice so, appreciate you sharing. Thank you so much Bhupinder for taking the time to join us today here at the 340B coalition conference, it's been great to discuss a subject that I know is so important to so many of the people here.
Bhupinder Carr (15:29):
Yeah, thank you so much for having me.
David Glendinning (15:31):
Our thanks again to Bhupinder Carr for sharing her take on 340B data analysis with conference goers and podcast listeners alike. Want to hear more from 340B experts? Register for the 340B coalition summer conference in Washington, DC on August 1st through 3rd. There are nearly 50 conference sessions and pre-conference workshops already planned and featured speakers include Carol Johnson, the administrator of the health resources and services administration and Dr. Emeka Egwim the new director of the HRSA office of pharmacy affairs, which administer 340B.
Early bird registration discounts for the conference expire soon, so be sure to visit the link in the show notes today, to learn more about the event and sign up to attend. We look forward to meeting more of you there. As always, we welcome your feedback and episode ideas. You can email us at podcast@340Bhealth.org. We will be back later in the month as always thanks for listening and be well.
Speaker 1 (16:39):
Thanks for listening to 340B Insight. Subscribe and rate us on Apple podcasts, Google play Spotify, or wherever you listen to podcasts for more information, visit our website at 340Bpodcast.org. You can also follow us on Twitter @340BHealth and submit a question or idea to the show by emailing us at podcast@340Bhealth.org.