A recent review and opinion piece, “The 340B Drug Discount Program, A Review and Analysis of the 340B Program” (the Review) , published by six trade associations to include: the Biotechnology Industry Organization; the Community Oncology Alliance; the National Community Pharmacists Association; National Patient Advocate Foundation; the Pharmaceutical Care Management Association; and the Pharmaceutical Research and Manufacturers of America, articulated some key findings that are consistent with and promoted by CaptureRx’s approach towards 340B management.
“We see this report as the first step to productive open dialogue among all the industry stakeholders to discuss solutions, and address issues regarding 340B,” states Jack Szczepanowski , JD, Chief Operating Officer of CaptureRx.
Although the Review contains multiple inaccuracies and misrepresentations, CaptureRx agrees with the Reviews call for greater transparency, assurance of benefit to appropriate patients, additional funding for the Health Resources and Services Administration for oversight, and clearer patient definition and hospital eligibility criteria.
However, at the core of the Review, the authors suggest that 340B’s sole primary purpose is to provide access to medications for the uninsured, and as is argued, with more patients becoming insured, the need for 340B is lessened. However, close to 30 million Americans are still expected to be uninsured after health reform is fully implemented.
Although one can ruminate about 340B’s intent, the greater question is “how can 340B be a positive solution, not just for safety-net providers and patients, but for society, the government and drug manufacturers alike?” We have serious health care issues and growing medical costs in America. Much of these costs are escalated by hospitalizations. There is no segment of population that contributes to this cost more than the aged, disabled, mentally health challenged, low income, disenfranchised, and health-illiterate. These patients are the super-utilizers exhibiting chronic co-occurring co-morbidities. These patients, which exemplify the safety-net patient, will always need more support services than the average American, regardless of whether they are insured or not.
The 340B drug program can be a primary vehicle targeting funds directly toward these chronic safetynet populations to not only assure that uninsured patients have access to medicine, but that all safetynet patients, insured or not, have access to better outcomes from the medicine. The cost to achieve better outcomes from the typical safety-net patient is greater than the average patient. 340B additional savings generated by insured patients, allows for the additional case management, health coaching, medication therapy management, and additional support services that safety-net patients require. Simply gaining access to medicine alone does not solve the healthcare dilemma. However, access to better outcomes, by keeping the patient continuously compliant on the medicine, does.
CaptureRx, in partnership with numerous 340B stakeholders, has been at the forefront of compliance initiatives including but not limited to the formation of its user group, Medicine Access and Compliance Coalition (MACC), which is an independent, not-for-profit coalition currently comprised of covered entities whose mission is to: 1) create the highest level of standards and practices through uniform policies and procedures with oversight and third party audit activities to assure compliance, 2) assure transparency and stewardship of pharmacy medicine discount programs, 3) promote and deploy medicine therapies and education programs to the most vulnerable patient populations mostly served by safety-net providers, and 4) advocate for medicine access through open dialogue with industry stakeholders, regulators and legislators.
In this context, CaptureRx is clarifying a misstatement by the authors in the Review, in a footnote reference to a CaptureRx brochure. The footnote was provided to show examples of alleged inappropriate interpretations of patient definition as it relates to hospital employees participating in 340B. What the authors fail to include is that in the same brochure, the first “benefit highlight” bulletpoint reads, “Assures compliance and audit ability by linking prescription with a medical record.” What’s more, it mentions that “savings can be realized from eligible employees’ prescriptions…”
The authors’ implications are misleading and are not, in fact, examples of diversion. CaptureRx’s technology is one of only a few companies that actually mitigates diversion by only approving 340B prescriptions that have first been matched with an eligible medical record, regardless of whether the patient is an employee of the hospital or not.
CaptureRx’s platform, required policies and procedures and compliance initiatives, promote and adhere to the key findings of the Review. Some additional considerations that were not clearly spelled out in the Review that are being discussed by safety net systems , regulators, States, manufacturers and managed care companies include but are not limited the use of 340B to promote medication therapy management programs, structure pharmacy homes, increase access to positive clinical outcomes through partnerships between network providers and managed care. CaptureRx agrees with most of the key findings of the Review. However, any draconian changes to the program need to be approached cautiously as certain limitations would jeopardize safety net networks, limit distribution channels for manufacturers and inadvertently cost shifts to the tax payer.
CaptureRx® provides pharmacy network administration, data and health technology solutions to support our nation’s safety-net hospitals, clinics and managed care organizations through 340B, GPO and Ownuse drug price savings programs. CaptureRx® serves our nation’s costliest and highest risk patients by managing outpatient prescriptions that comprise 80% of today’s patient’s treatment modality. CaptureRx® identifies, tracks and navigates high-risk populations within medical and “pharmacy home” networks to assure access and adherence, as well as better outcomes. Visit www.capturerx.com.
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