340B Insider – March 2016

    Welcome to the March edition of RxStrategies 340B Insider, a concise communication to provide a quick highlight of updates from RxStrategies’ view.


    Recently, the RxStrategies experts attended 340B University, presented by Apexus, to gain further insight regarding current 340B trends.  The following are highlights from a recent session:

    1.) 340B Mega Guidance: Over 1300 comments and questions were submitted during the 60- day comment window for the proposed Mega Guidance published August 28, 2015.  Each comment and question has to be reviewed individually by HRSA.  Apexus indicated that the timeline could be one – two years before the finalization and release of the Mega Guidance.

    (source: 340B Health)

    • RxStrategies Response: RxS proactively put together a set of questions based on feedback from our clients and submitted the list prior to the submission window of October 27, 2015. We are excited to work with your Covered Entity (CE) to help ensure the continued compliance of your 340B program.

    2.) 340B Program Integrity: As much as 35% of audits are triggered by discrepancies on the OPA database. The CE’s OPA database needs to be maintained by a member at the CE.

    • Apexus 340B University: Good Practices to Consider – CEs should have written Policies and Procedures pertaining to the prevention of duplicate discounts, managing the OPA database, and updating provider files regularly.

    3.) Compliance  and Recertification:  Apexus recommends that CEs perform monthly self-audits on its 340B claims. Entities are required to recertify information on the HRSA 340B database annually. HRSA sends a notification email to the authorizing official and Primary Contact containing a username and password (authorizing official). Then the authorizing official is able to perform the recertification online

    • RxStrategies Response: 340B Compliance Plus provides your CE the ability to meet or exceed the recommended self-audit criteria outlined by Apexus and HRSA.

    Ready to learn more? We believe the 340B University is a valuable resource, and we encourage our RxStrategies team members, as well as our clients, to consider attending the sessions. Visitwww.340bpvp.com for more information.



    RxStrategies introduced an enhanced booth and related materials, at the 340B Coalition Winter Conference in San Francisco.


    During the 12th Annual 340B Coalition Winter Conference, our team networked with industry leaders to discuss HRSA’s proposed mega-guidance and gain further insight on issues impacting the overall market. The sessions were informative and included the following:

    • Updates from the Office of Pharmacy Affairs and Apexus on the status of the 340B program and their plans for the future.
    • HRSA’s proposed mega-guidance is still under review and is not likely to be issued until 2017.
    • Updates from Washington, DC on key legislative matters impacting the 340B community and possible changes in store for the program.
    • Detailed discussions of HRSA’s proposed patient definition guidelines.

    340B PAC

    As an active 340B PAC advisory board member, RxStrategies was pleased to be in attendance during The Friends of 340B PAC Reception held during the conference. Through these efforts we work with other industry leaders to promote the integrity and longevity of the 340B Program. RxStrategies proudly supports the enhancement of the knowledge of legislators as to the critical nature of the program and the needs of patients involved. To learn more about the PAC, reference www.friendsof340bpac.com.

    RxStrategies’ Increased Presence at 340B Coalition Winter Conference

    It was great to connect with so many industry leaders during the conference.  Thank you to those who were able to stop by our booth or visit with the RxS team between sessions. In addition to being aPinnalce Leader Sponsor of the conference, RxStrategies showcased a new booth design, our comprehensive Compliance Plus and Split Billing solutions, and demonstrated our enhanced client portal and reporting capabilities. For further information or to request a demo, contact us.




    340B Health is proactively generating informational materials and has ramped up its advocacy efforts to educate key decision-makers about the overall value of the 340B Drug Discount program, including:

    – A new educational video explaining the 340B Drug Discount Program. Watch the video>

    – Recently published articles

    – Sample communications templates for DSH and Rural hospitals to use for emphasizing the challenges to meeting the needs of vulnerable populations.

    – A member survey report detailing the impact of 340B on underserved populations will be published in the near future.

    Please contact us to discuss how RxStrategies may assist with additional information and support. 


    RxStrategies Welcomes New Team Member
    We are pleased to introduce Russell Crane as Sales Manager – Northeast Region. He joins the RxStrategies’ sales team and has responsibility for sales and delivery of customized 340B pharmacy administration and split billing solutions to providers located in the Northeast Region. Read more>


    Join the RxStrategies’ team at the following upcoming conferences:

    NACHC Policy and Issues Forum
    March 16 -19 | Washington, DC
    Learn more. 

    VA Community Healthcare Association Meeting
    June 7 – 8 | Henrico, VA
    Learn more.

    North Carolina Primary Care Conference
    June 9 -11 | Durham, NC
    Learn more.

    340B Coalition Summer Conference
    July 11 – 13 | Washington, DC
    Learn more.