This is part 6 of our latest Webinar Rewind, “Understand & Prepare for the Virtual HRSA Audit Experience” with experts Larry Crowder, Cervey’s Vice President of 340B Solutions, and Maggie Williams, Pharmacy Director of White River Medical Center. Crowder and Williams participate in a Q & A session following the webinar.
Missed the earlier Webinar Rewinds for “Understand and Prepare for a Virtual HRSA Audit?” Catch them here:
Part 1 | Part 2 | Part 3 | Part 4 |Part 5
Question:
Are there different audit processes per CE type? What if there are no 340B administered drugs at our CHC?
Answer:
Larry Crowder:
If you don't have a pharmacy, it's going to be a different look when you're getting audited. If you do have a contract pharmacy network, it's still going to apply to you these things that we're saying, they're still going to ask for all the data for six months of eligible scripts that had gone to the contract pharmacies, and they're still going to pick 28 claims from there and do that review, but it's different for each person. If you go to 340B.com they will have tools for your facility of things to check and things to look for, to be prepared for an audit and how you do yourself checks and how you make your policy and procedures. I highly recommend that site.
Question:
Do they verify the status at the time of dispense or is it at the time administration?
Answer:
Larry Crowder:
That's another good question. The mega guidance that was going to come out in 2016 stated that they would like you and this did not go into effect, so don't have heart attacks anyone, this didn't go into effect, but it stated that they wanted you to use final status. Basically, if the patient went to ER, but was later admitted, then they wanted you to use that final status. Therefore, everything even given to them in the ER, was going to be inpatient. Most systems don't do that. Most systems do status at time of dispensation. The auditor will come back to your EMR system and they'll look for when they become inpatient. For example, it's 11 o'clock, they're in the ER and they're outpatient, and you dispense a drug that is eligible, but you need to be able to show the timestamp of when they then became inpatient. So, if they then become an inpatient until 1:00 PM then you would be good in that circumstance.
It's not many, but I have a few accounts that actually do final status. So essentially, they have a delay in their file that comes up two weeks to make sure it was final status before they give it to you. It's nice for the auditors, technically for them to go in and say, okay, there's the status? And there's the patient. And it always matches, but obviously you're going to lose out on a lot of 340B savings if you're not taking advantage of the outpatient that's being dispensed at the time of dispensation. So, you want to make sure that you make that decision for you, but I would say that 90% or more are doing it at the time of dispensation.
Question:
When we have an independent audit, should it be a whole program audit or just a portion contract pharmacy mixed use, etc.?
Answer:
Larry Crowder:
I recommend the initial deep dive on it; I think it's worth the money. If 340B is saving you a good amount of money and is worth that peace of mind to have the deep dive of somebody coming in that has seen other accounts, have seen other hospitals they've seen your FQHC or whatever your entity status is, and they can come in and they can really look into the deep corners and dark areas of your program and make sure everything's good. After you get that deep dive in, then I would recommend doing the mock audit; just the typical HRSA audit, where they come in and they act as if they're HRSA and they do the mock audit and do that at least once a year. So that would be my recommendation and Maggie, I'll let you speak to what you guys do.
Maggie Williams:
We have a group that monitors all of our contract pharmacies on a regular basis. We pay this group, they do our quarterly audits and they go deep into the contract pharmacy. They get down and they'll look at our Medicaid duplicate discount on a regular basis. It's an ongoing survey of our contract pharmacies and we pay for it, but it's worth it because to me that's our biggest issue is in contract pharmacies. But in our mixed use we do our own internal audits, but I would recommend, like you said, do a deep dive. You don't know sometimes what's happening until you really get in there and start looking. I would recommend that as well.
Question:
What's a 340B Universe?
Answer:
Larry Crowder:
A 340B universe is a high level of what area is being dispensed. For instance, your main hospital that has a mixed use pharmacy is one 340B Universe. Your contract pharmacy network is another 340B Universe. Your clinics would be a third 340B Universe. Those are three different universes, but they're all interconnected together. But when they pull claims and when they look at the 28, claims are going to look at each area, they're going to take each universe and pull 28 claims for those universes.
Question:
Is a physical command center required for a virtual audit?
Answer:
Larry Crowder:
It is not required. I think Maggie did it for herself, there were some benefits to that because they could use the audit area and they could have a discussion amongst themselves and then unmute. But I have known that we had other accounts that everybody was at home during the audit. But you do want this idea of having your command center, whether it's virtual or in person, so that you have all the key players and key personnel in there so that you can answer the auditor's questions.
Final Thoughts From Larry Crowder
Preparation is key. You want to make that audit day very peaceful and friendly to you. To do that, do your self audits, have an independent party, come in and look at your processes and make sure that you're doing everything that you can to be compliant and then putting in that daily, just self-checks and looking at your data and doing that now so that when you do get that HRSA letter, it's not going to be anything that you have to stress over. That's what we don't want. We don't want everybody out there stressing about it because the day of the audit is really the easy day.
Ready to make 340B program audits, virtual or in-person, easier on you and your team? Contact us for a demo of our 340B suite of web-based products that help 340B-eligible healthcare providers with three of their most pressing 340B needs: maximizing savings, ensuring compliance, and optimizing the performance of their contract pharmacies.
Looking for the rest of the webinar series? Check out parts 1-5 below:
- Webinar Rewind: Virtual HRSA Audit Part 1
- Webinar Rewind: Virtual HRSA Audit Part 2
- Webinar Rewind: Virtual HRSA Audit Part 3
- Webinar Rewind: Virtual HRSA Audit Part 4
- Webinar Rewind: Virtual HRSA Audit Part 5