How to minimize the operational burdens of claims data submission and improve performance.
The 340B ESP™ platform provides an opportunity for Covered Entities (CEs) to regain access to 340B pricing, allowing for the continuation of support for underserved and uninsured patients. Unfortunately, the complexity and timeliness issues inherent in managing 340B ESP™ have created several new challenges.
Current 340B ESP™ landscape
A growing number of manufacturers have imposed significant penalties restricting 340B pricing at Contract Pharmacies over the last several years. Several of them offer to restore pricing if claims data is submitted through the 340B ESP™ platform, but the process isn’t the same across all manufacturers. Others allow CEs to designate a single Contract Pharmacy to receive 340B pricing, but only if the CE has no owned retail pharmacies.
These challenges have resulted in a 340B ESP™ process that’s often difficult for CEs to navigate. Claims data submission can be an operational burden, especially for CEs with limited 340B resources. And keeping up with the many moving parts and restrictions involved in 340B ESP is often a daunting task.
So, what can CEs do to manage 340 ESP™ compliance and optimize their program performance? Visante offers five practical tips for success:
- Streamline data submission.
It’s important to be familiar with the capabilities of your Third-Party Administrator (TPA). Many TPAs will have a standard report, but if they do not, utilize a claims detail report and filter for only the required fields and NDCs. Note that you can download a restricted NDC list from the 340B ESP portal.
- Establish audit practices among TPAs and wholesalers.
It’s important to routinely audit reports provided by TPA and wholesaler pricing catalogs. Visante recommends using the restricted NDC list to validate that only claims for restricted NDCs are present on TPA reports.
Once pricing is restored for an NDC, a 340B pricing contract will be loaded into the wholesaler portal. To validate pricing, identify a product catalog report from the wholesaler that contains pricing and contract loads. Then you can become familiar with the process that different TPAs use to block NDCs, as each TPA may vary.
Know that pharmacies can and do lose pricing eligibility after it has been restored if their purchase volume is higher than the quantity of claims submitted. That’s why it’s very important to regularly review your 340B ESP™ pharmacy eligibility.
- Track pricing restoration.
After data submission, pharmacy eligibility will be updated within the 340B ESP portal. Pricing is typically restored with the wholesaler within several weeks or months of eligibility in 340B ESP. Then you can work with your TPA to identify what method was utilized to block restricted NDCs. Note that your TPA should be able to provide you with a report listing the block status for all restricted NDCs.
- If the TPA has an automated review process, they can unblock NDCs with restored pricing.
- If the TPA does NOT have an automated review process, price restoration must be identified through the wholesaler catalog and communicated to TPA.
Visante also recommends periodically reviewing price restoration to identify any new NDCs that have had pricing restored, or NDCs that have lost pricing.
- Report on price restoration
The timeline from initial data submission through first purchase at restored pricing can range from 3-8 weeks, depending on the capabilities of both the TPA and wholesaler.
Most TPAs have an impact report available to identify losses from restrictions and gains from price restoration. For TPAs without a standard report, this can be done utilizing claims reports and matching qualified claims to the restricted NDC list. You can validate the actual purchase price using wholesaler invoice reports.
- Follow these tips for ongoing success
Visante’s 340B consulting practice has successfully supported dozens of clients with various aspects of 340B ESP™ submission and revenue recovery. This is our top advice to ensure future success:
- Stay in regular communication with vendors (TPAs, Wholesalers)
- Identify a primary resource that is proficient in Excel – and have backups
- Routinely monitor pharmacy eligibility in 340B ESP™
- Ensure key stakeholders are registered with 340B ESP™ so they receive emails and notifications
- Participate in any webinars offered by 340B ESP™, as the system is often upgraded
For more information on these five practical tips to navigate 340B ESP™ and optimize your program, please email firstname.lastname@example.org or call (866) 388-7583 to talk to one of our team members.