Under the direction of the Pharmacy Director, the 340B Program Coordinator provides oversight and leadership from the department of pharmacy for the 340B Program. The Coordinator serves as the hospital's compliance expert on 340B Program details, policies, and procedures and acts as the liaison with necessary affiliated departments to ensure hospital 340B Program integrity. The Coordinator leads the organization's 340B oversight committee which includes members from senior leadership, pharmacy, compliance, legal and finance. The Coordinator oversees and provides leadership to specific 340B-related activities such as policy and procedure development, rules/guidance surveillance, registration and recertification, self-audits, external audits, 340B contract management, program enhancement and optimization, reporting, purchasing and inventory oversight, and split-billing software maintenance as outlined in the Duties and Responsibilities.

EXEMPT

Ensures that policies and procedures are developed, implemented, and maintained according to organizational, regional, national, state, and federal requirements and guidelines, and are approved by the hospital's legal counsel.

Establishes consistent policies and procedures for 340B that ensure productivity and efficiency so that long-term management of the program does not hamper operations or create unnecessary costs.

Provides ongoing training, education, and communication required for the 340B Program at the organization, including training/competency materials for all employees who work with the 340B Program.

Regularly communicates with all staff involved with the 340B Program to be sure that processes remain efficient and to address any problems or suggestions for improvement.

Monitors and assesses 340B guidance and/or rule changes, including, but not limited to, HRSA/OPA rules and Medicaid changes.

Participates in regular 340B-related trainings and shares lessons and hot topics with others in the organization.

Routinely monitors industry publications and websites as well as the professional media, literature, and peers to ensure that the institution has the latest information regarding interpretations, rulings, suggestions, and advanced ideas for improving participation.

Strives to ensure that the Hospital 340B Program is continuously compliant with 340B federal regulations.

Provides expertise on all 340B Program legislation and policy changes from HRSA and OPA, informing and collaborating with legal and compliance teams.

Responsible for ensuring that the annual HRSA recertification is completed within the allowable time frame.

Responsible for ensuring that the HRSA 340B OPAIS is accurate for all organization entities.

Responsible for ensuring registration of any new child sites within the allowable time frame.

Develops, executes, and documents self-audits of all points of service where 340B participation occurs to ensure policy and procedure compliance, covered entity eligibility, and "covered patient" eligibility Coordinates and ensures remediation of findings.

Conducts and/or coordinates an annual audit of all contract pharmacies. Documents results and follow-up on any findings.

Monitors utilization records and 340B purchasing accounts to ensure that software or tools are working properly and accurately, performing audits or compliance assessments internally as needed; coordinates external compliance assessments with outside firms, when appropriate, to validate internal processes.

Evaluates patient eligibility for qualified and non-qualified patients in hospital-based mixed-use areas and clinics by reviewing patient medical records, insurance plans, and hospital status.

Responsible for the day-to-day management, compliance review, and operations of clinic-administered medications in eligible locations, mixed-use areas managed by split-billing software, outpatient prescriptions fulfilled by an owned pharmacy, and outpatient prescriptions fulfilled by a contract 340B pharmacy.

Performs 340B purchasing and utilization audits or compliance assessments internally, as needed.

Serves as the point person and coordinator for all audits. Coordinates all requests and responses.

Maintains a current state of "audit readiness."

Assists Pharmacy Director with review and negotiation on new 340B contracts.

Maintains electronic files of all 340B related contracts in a manner easily retrievable for audit.

Assesses opportunities for cost savings, compliance enhancements and business development in 340B contract pharmacy portfolio.

Analyzes utilization of the program and existing software to identify ways to compliantly use the 340B Program to its fullest extent to meet the needs of underserved patients.

Works together with manufacturers and wholesalers to develop strategies to appropriately use the program to its fullest extent to meet the needs of underserved patients.

Implements business plans in coordination with organizational leadership to help use 340B savings to expand and improve care provided to underserved and vulnerable populations.

Routinely monitors monthly and annual reports on 340B participation that clearly document utilization, savings, problem areas, and exceptions or discrepancies, to be passed on to pharmacy leadership, 340B Sub-Committee and Senior Leadership.

Develops and reports appropriate financial metrics to assess program performance and opportunities for improvement.

Develops and reports appropriate compliance metrics to assess program integrity/audit readiness and opportunities for Improvement

Coordinates monthly financial reporting and analysis, including, but not limited to, key performance metric reporting, dashboards, variance analysis, risk and opportunity reporting

Develops routine reports that are a by-product of the purchasing, utilization and inventory process and software, allowing for concise information to be communicated those responsible for 340B inventory management.

Routinely communicates any questions, issues, or discrepancies with the appropriate authority.

Routinely or as directed to, performs opportunity and/or risk analyses related to program changes.

Ensures appropriate documentation and audit trail across areas of responsibility.

Monitors purchasing records for each 340B participant; clearly documents utilization, savings, problem areas, and exceptions or discrepancies. Relays results to pharmacy leadership.

Monitors for 340B pricing exclusions or shortages and establishes appropriate alternative products that are included when possible, including work with Pharmacy Leadership team and formulary to ensure proper position and related use.

Participates with the Prime Vendor and routinely reviews 340B formulary pricing, potential alternatives, and possible additional savings as a result of GPO formulary.

Continuously monitors product min/max levels to effectively balance product availability and cost- efficient inventory control.

Maintains system databases to reflect changes in the drug formulary or product specifications, communicating across disciplines to revenue, coding, and other stakeholders as applicable.

Routinely monitors utilization records and 340B purchasing accounts to ensure that software or tools are working properly, tracking 340B drug inventory and replenishment.

Performs thorough quarterly reviews of the new 340B pricing list to search for and quickly address costly changes.

Oversees 340B regulatory aspects of the inventory purchasing process for outpatient, inpatient, and mixed-use areas.

Establishes a routine approach to updating the CDM/crosswalk for new products and product changes to ensure both the accuracy of the utilization report and the efficiency and accuracy of the charge process.

Maintains 340B split-billing software integrity and reviews applicable reports to identify areas for improvement.

Assists in implementing new software packages and other changes in business practice based on changing regulations and policies.

Integrates information from the pharmacy chargemaster system into the 340B split-billing computer system and incorporates that information into auditable and compliant processes.

Works with outpatient pharmacy management and pharmacy informatics teams to ensure that the organization's clinical information system is coordinated and integrated into the work with the 340B Program. This shall include the electronic interfaces between the EMR and the virtual accumulator and any interfaces between the organization and contract pharmacy providers and/or administrators.

Periodically performs spot audits or compliance assessments in specific areas and specific products to ensure that the CDM is accurate, charges are coming across accurately, and the utilization numbers are translating accurately into report for 340B reorders.

Demonstrates the ability to deal with pressure to meet deadlines, to be accurate, and to handle constantly changing situations.

Demonstrates the ability to deal with a variety of people, deal with stressful situations, and handle conflict.

Professional Requirements:

Adheres to dress code.

Completes annual educational requirements.

Maintains regulatory requirements.

Wears identification while on duty.

Maintains confidentiality at all times.

Attends department staff meetings as required within the department.

Reports to work on time and as scheduled; completes work in designated time.

Represents the organization in a positive and professional manner.

Actively participates in performance improvement and continuous quality improvement (CQI) activities.

Coordinates efforts in meeting regulatory compliance, federal, state and local regulations and standards

Communicates and complies with the Benefis Health System Mission, Vision and Values as well as the focus statement of the department.

Complies with Benefis Health System Organization Policies and Procedures.

Complies with Health and Safety Standards and Guidelines.