Speaker 1 (00:05):
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 Paul Mollo with the health system, Ascension. Paul oversees the 340B program at Ascension at a national level, and he is a member of the board of directors for 340B Health. We recently caught up with him at the 340B Coalition Winter Conference in San Diego to discuss how hospitals can build a team of professionals to run their 340B programs. But before we go to that interview, let's take a minute to cover some of the latest news about 340B.

David Glendinning (01:03):
The federal office that oversees 340B has a new leader. Emeka Egwim has been appointed Director of the Office of Pharmacy Affairs at the Health Resources and Services Administration. He succeeds Krista Pedley, who was OPA Chief for more than a decade before her promotion last year to run the new Office of Special Health Initiatives at HRSA. After receiving his doctor of pharmacy in 2011, Egwim entered public service with OPA where he worked on 340B issues. Some of his more recent experience at the agency has involved policy and clinical work related to the Medicaid drug rebate program and The Ryan White HIV/AIDS Program. You can learn more about Egwim in the show notes.

David Glendinning (01:48):
Also in the show notes are a trio of letters from 340B Health about the contract pharmacy dispute. One of them is addressed to Health and Human Services Secretary, Xavier Becerra, HRSA Administrator, Carol Johnson, and other federal officials. It outlines the increased pressure some drug companies are placing on hospitals to hand over contract pharmacy claims data, as well as the legal, financial and administrative burdens these demands are causing hospitals. The other 340B Health letters went out to the CEOs of AbbVie and Bristol Myers Squibb urging the companies to abandon the restrictions they recently imposed on 340B pricing through contract pharmacy partnerships.

David Glendinning (02:38):
And now, for our feature interview with Paul Mollo. Paul is the National Director for Medication Outcomes Disparity for Ascension, where he oversees the multi-state systems 340B and patient medication assistance programs. So he knows what it takes to stand up a 340B program and staff it with the right people. Miles Goldman recently sat down with Paul in our podcast studio at the 340B Coalition Winter Conference to learn more. Here's that conversation.

Miles Goldman (03:09):
Thank you, David. I'm joined by Paul Mollo from Ascension. Paul, I'm looking forward to a great conversation on building a hospitals 340B team, which I know you have a lot of experience in. Welcome to 340B Insight.

Paul Mollo (03:24):
Well, thanks for inviting me, Miles. Great to be here.

Miles Goldman (03:28):
How did you start working in 340B and what made you interested?

Paul Mollo (03:32):
Well, interestingly, I was a director of pharmacy for quite a while, as I think a lot of people in the 340B program kind leadership kind of come up through, directors of pharmacy, and I always had a lot of interest in medication affordability programs and helping the poor and vulnerable in our population, and then my hospital was able to qualify for 340B at one point and I got really deeply involved in that program, saw it's possibilities and potential for helping me support that population of people. So started to develop my team and we were able to really grow our program and see a lot of great results from it. So from there, I had the opportunity to move into a national role at Ascension doing 340B. And I just love the program because it really does help a lot of people.

Miles Goldman (04:21):
I think that's a good segue into just telling us more about Ascension and where it's located and how it organizes staffing its 340B program.

Paul Mollo (04:30):
Sure. Ascension is a 142 hospital system. Of those hospitals, 50 of them are covered entities, are basically eligible for the 340B program. Ascension being a Catholic health system, it's really important to understand when we look at the 340B program, we look at it through the governance and these principles. And I just always like when I talk about Ascension and I talk about 340B, I always like talk about these principles because I think they're important. And the principles are this. One is that the benefit generated from the program are essential for Ascension's mission and are used to provide services to those who are poor and vulnerable. We also basically state that Ascension's participation in the 340B program should serve as a model for others to follow, and that our 340B program must be amounted with integrity and in the manner that aligns with our mission, vision and values.

Paul Mollo (05:26):
So we kind of look at those principles and then we build off of that, and it plays into how I staff because we want to have integrity. And in order to have good integrity, good compliance, you have to have staffing in order to make that happen. Our program runs over of 12 states, so I split those up into eight markets. We have 26 dish hospitals, 18 critical access hospitals, and then we have basically six hospitals, our rural referral centers. We have a sole community hospital. We have a community health center. So we pretty much run the gamut of different 340B hospital types. So from the standpoint of organizationally, they hired me to be the national director over the 340B program, and then I have nine 340B directors in each of those markets who run the program at the at level and then we have analysts down at the local level. So we kind of look at it from a national market and local level. I always say it's a national program with a local field.

Miles Goldman (06:27):
Understood. When I think about the market level, it makes me think about, too, just how there are different needs in different regions of the country that I imagine make that really helpful to have that structure.

Paul Mollo (06:42):
Oh, absolutely. And some of my market leaders oversee multiple states and every state is a little bit unique on how they do things like Medicaid, for example, carve in/carve out, fee for service. All those things are state driven, so you have to know a lot about what's happening in those states. So state advocacy as well; keep your finger on the pulse of what's happening in your market. So it's really important to have that market level leadership.

Paul Mollo (07:09):
The other beauty of this is that when I look for people, and I know we'll probably talk about this a little bit more, but when I look for people, I look for people with different strengths so that all of my team members bring something different. Some have an IT background. Some may have a management background. Some may have an operational background. So all of them together brings something to the team. And so when we work together, we have a committee that oversees all of the 340B program that meets once a month and that governance committee also includes legal. It also includes compliance on that group and advocacy as well, and we all work together to kind of structure where we're going with the 340B program moving forward.

Miles Goldman (07:54):
Are there some other types of skills, you just mentioned IT, you're looking for when building the team?

Paul Mollo (08:00):
Yeah, it's really interesting. In order to be a good 340B leader, one, you have to be able to manage complex situations and deal with all the issues that we face in the 340B program. But the other thing I look for is people are mission oriented because it's very important that people understand that this 340B program, even though it creates financial benefit, it's supposed to be used for the poor and vulnerable populations, and all of my team members understand that. So I look for that to be instilled in somebody when I look to hire somebody. So their backgrounds come from various places. Like I said, we have people from IT. We have people who are pharmacy to directors who moved into a 340B role. We have others who are pharmacy technicians who've rolled up and became pharmacy managers and then 340B directors. We've had all different types of people, usually with some sort of background where they kind of manage sort of a business background. We have a lot of MBAs as well in our program.

Miles Goldman (09:00):
I was going to say, do any come from the finance department itself?

Paul Mollo (09:05):
I actually do have some analysts who rolled over to us from the finance department. They make great analysts actually, because they know how to understand analytics. There's a lot of complexities in the billing and rev cycle with 340B. So having that expertise is something I do look for, but it was funny because it's always controversial in a way to say, "Should they have a pharmacy background or not when they get into it?" What can you give them? You know? And so I look at my team as a whole and just say, "What am I looking for that I don't have?" Right?

Miles Goldman (09:40):
That makes sense. How do staffing needs differ based on the size of a hospital? I'm wondering, do most systems like yours organize things at the system level or at the local level from what you hear?

Paul Mollo (09:55):
That's interesting question because I do have a lot of colleagues out there who are part of large 340B systems, like they have multiple covered entities like I do. It's funny. Everybody does it a little bit uniquely. I think for the most part, there usually is someone who's overseeing the 340B program in totality. I break mine up and I have this program manager, program director, program leadership level at the market level. That's one thing that's kind of unique. You don't always see that. So a lot of times you'll see that they'll have a bunch of analysts and then they roll up to one single person. Essentially a very complex organization, it really wouldn't work that way well for us, but I've seen other organizations function that way.

Miles Goldman (10:42):
Can you describe whether the needs for a 340B team have changed over time?

Paul Mollo (10:49):
Absolutely. When the program first started, we didn't have a lot of technology. You kind of managed it pretty manually and it was very difficult to understand what qualified and what different. And then as technology gained in the programming and you started to see more and more vendors get involved, the complexities actually increased a little bit. So you do need a skilled staff who understand the importance of compliance around 340B. So I think it's important that people understand that you have to staff the program in order to make sure that you're 100% compliant with the program at all times.

Miles Goldman (11:31):
You've mentioned the increasing number of people on your team with MBAs. I'm wondering for someone who's listening to this who doesn't have an MBA, but wants to maybe grow their role in 340B, would you recommend that they go and get an MBA, or maybe is there some other sort of business credential that they could get that also would be helpful?

Paul Mollo (11:56):
I think an MBA is good because what an MBA does is it really helps you to understand how to manage data. There's a lot of finance, a lot of data, a lot of things that go into the 340B program, and those who have an MBA seem to be able handle that very quickly. Where they lack sometimes is on the pharmacy knowledge side of things. So you have to balance that with somebody who has pharmacy experience. So like your pharmacy technician, for example, who's worked in a hospital or in a retail setting, that person, even though they may not have that MBA background, they bring that pharmacy component to it and then we have to teach them sort of the accounting, the spreadsheet data analytic component to the process.

Paul Mollo (12:39):
But I think together when you have those two people together working with each other and leveraging each other's strengths and weaknesses, you have the best program. So I wouldn't say go out and get an MBA. I would say, if you're interested in 340B and you have a 340B program at your hospital, let your 340B program leader know that you're interested in that program and maybe there's something you could do to get started or help on a PRN or per diem basis to kind of get your feet wet. And then when a position opens up, you're already educated and trained in that.

Miles Goldman (13:13):
Are staff working on 340B dedicated to working on the program, or are they also working on other issues in pharmacy or finance, et cetera?

Paul Mollo (13:25):
These are interesting times. For the most part, my 340B leaders are all pretty dedicated to the 340B program for a large portion of what they do every day. We have been getting them more involved in the medication disparities component of the work I do as well because I feel like that ties in really good. But on the analyst level, the ones that are pharmacy technicians I see, or we pharmacy buyers, who also make really good 340B analysts as well because our buyers are really important, but I see them getting sort of usurped back into their old jobs because there's such a need over there that we've had to share our people, keep our program running, but at the same time, make sure we help keep the core service lines of the hospitals that we work inside of still running. So some of them do sort of a hybrid role where they'll still be a pharmacy technician or a pharmacy buyer, but for the most part, their primary responsibility is 340B analytics.

Miles Goldman (14:28):
I want to talk more about hiring of staff on your 340B team. Do you have a rule of thumb for determining when you are understaffed versus sufficiently staffed to manage your 340B program?

Paul Mollo (14:42):
Yeah. Actually, when I first started in my role, we didn't really have a rule of thumb and one of the things I thought was lacking was some sort of objective criteria we could use when we looked across the different markets and we saw a large variability in the staffing models that we had, and as well as there was a lot of variability in the tools we were using as well. And so we started working on, how do we standardize those tools and then come up with a methodology for sort of looking at our staffing map models objectively, taking into consideration, lots of things. Like I said, 340B is pretty complicated. Every hospital or participant in the program could have different complexities and need different staffing models. So there's not really a one size fits all, but we did work as a team to come up with a rule of thumb and some criteria that came up with in order to determine sort of what a baseline staffing level should be.

Paul Mollo (15:35):
It's really based off of what type of hospital you are; if you're a dish hospital, if you have a lot of child sites, if you have a lot of contract pharmacy arrangements. That's a pretty complex environment. It may need more staffing than a critical access hospital, for example, or a small rural a referral center. So we kind of took all of these different size hospitals and complexities and came up with sort of a rule of thumb as to how many analysts you would need, or even managers, or supervisor level people in your program in order to keep it operating compliantly and with that integrity that we always talk about.

Miles Goldman (16:11):
Are you from it easier or harder to recruit the right people right now to your 340B teams? We keep hearing about overall challenges in healthcare staffing.

Paul Mollo (16:22):
COVID really changed everything for us as well. I was pretty much a remote employee before COVID hit, so I was really used to working remotely. But when COVID happened and we were shutting down our hospitals, non-essential workers were sort of moved and told to work from home, we were able to actually look at, do our analysts and our 340B leaders need to be in the hospitals where they normally worked? And we found that we could actually do a job really well from home and it remotely. So what that did for us was really opened up the fact that if I have a program in Indiana, I don't necessarily have to recruit analysts from Indiana now. I can recruit from all over the country. And we do, and we actually have an analyst that lives in Florida who works in the program in Indiana.

Paul Mollo (17:11):
So what that allowed us to do has really increased the number of potential people who could apply for our jobs. So we've actually seen when we have open positions, quite a few applicants. They can work remotely, which is attractive, I think, in some instances. But at the same time, we can look for people who are in all these other states that we were never able to really look at before. So there's a lot of people out there with some pretty good 340B experience. So I've been pretty lucky to have quite a few good applicants for the job openings that I've had because of that.

Miles Goldman (17:44):
How might hospital 340B teams continue to evolve in the coming years?

Paul Mollo (17:50):
Well, I think with anything else, technology is evolving. And one thing we did was we tried to standardize everything, so that no matter what program you went to and what state you were in, you were using the same tools. So to me, the next sort of evolution for us as far as staffing is concerned, is being able to leverage our staffing across different markets because right now, you kind of hire into a market and they kind of focus on that market. And I think the next evolution will be people will be working in a 340B program and maybe they worked in Wisconsin, for example, but there's skillset is needed in Florida and I can leverage that person down in Florida. So I really want to see us take that analyst community mainly and start to get them integrated and working together and using their strengths and weaknesses and supporting each other, so that we can elevate our program moving forward.

Miles Goldman (18:46):
Paul, this has been a really fascinating conversation about professional development and the roles that different 340B professionals play on the team to help run an efficient and compliant program. Thank you so much for taking the time to speak with us here at the conference.

Paul Mollo (19:03):
Hey. Well, thank you, Miles. Always appreciate having the opportunity to talk about the program, Ascension and the great people who work for me. So really do appreciate you having me.

David Glendinning (19:11):
Our thanks again to Paul Mollo for the helpful primer on staffing and growing a hospital 340B program. We appreciate his willingness to share this expertise with so many others in the 340B community, and we thank him for his dedication to the future of 340B through his service on our board of directors. We will be speaking with 340B Health President and CEO, Maureen Testoni, again, soon to catch up on the latest developments in 340B. If you have suggestions about topics you would like to hear Maureen cover, you can email that feedback and any other episode ideas to podcast@340bhealth.org. We will be back in a couple of weeks. As always, thanks for listening and be well.

Speaker 1 (20:01):
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.