Process:  340B Program contract pharmacy oversight is no less challenging than oversight in the mixed-use (to include clinic and floor stock) space.  Because many contract pharmacies have dedicated split-billing vendors, a large contract pharmacy network often involves multiple split-billing systems which are not designed to interface/integrate.  Upon our initial audit, Visante realized that there were numerous contract pharmacy locations that had no dispensing activity over the course of six months, and many that had very low dispensing volume (less than 15 dispenses total over the course of six months, for non-specialty medications).  It is important to distinguish that low volumes for generic or brand medications are a different consideration than specialty medications.  Additionally, there were several contract pharmacy effective dates on the OPA website that did not correspond with the contract signature dates which resulted in dispensing occurring prior to the official “effective date.”  Lastly, there were multiple split-billing vendors in place for contract pharmacy dispenses, and when tested against the contract pharmacy locations with minimal to low volume, it was determined that two of the split-billing platform relationships could be eliminated.

Results: In just six months, the Visante team worked with the Covered Entity to make major changes to its contract pharmacy operations and develop a strategy that will set them up for long term success. Specifically:

  • Visante successfully supported an update of the OPA database to remove all locations with minimal to no volume over the course of six months.
  • The team removed a number of contract locations after determining that were multiple barriers that would take several more months or longer to overcome.
  • Visante reviewed e-prescribing data and history to determine where prescriptions were going, and created a contract pharmacy strategy focused around Covered Entity detail that was real and meaningful.

Stats: As a result of Visante’s external audit, we were able to determine that the Covered Entity was successfully under-resourced for their contract pharmacy network size (pre and post our audit support). Taking into consideration the new contract pharmacy network size and scope, Visante recommended 3 additional resources to allow the Covered Entity to support the necessary compliance oversight to be successful.  These resources were approved by senior leadership.