Health Resources and Services AdministrationOffice of Pharmacy Affairs

340B Peer-to-Peer Program

*The 340B Peer-to-Peer Program operates under a Health Resources and Services Administration contract with the American Pharmacists Association Federal Contracts and Grants. The intent of this program is for 340B Leading Practice Sites and Subject Matter Experts to share

their operational best practices and not the official policies of the Office of Pharmacy Affairs. The mention of trade names, commercial practices, or organizations does not imply endorsement by the U.S. Government. Additionally, your practice setting may require differences to

ensure 340B program integrity and meet all state or federal requirements.

January 13, 2016 2:00-3:00 PM Eastern

340B Compliance Improvement Series: Education and Training

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We encourage you to submit

questions throughout the

presentation through the chat function of the

webinar.

340B Webinar

Q&A – for questions

Download Slides

Links

Closed Captioning

Full Screen

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Financial Disclosure

Zandra Glenn, PharmD; Anne Marie Kondic, PharmD; Deborah Brafford; Heidi Larson, PharmD; Robert Butcher, RPh; and Diane Martin, RPh declare no conflicts of interest or financial interests in any product or service mentioned in this activity, including grants, employment, gifts, stock holdings, and honoraria. For complete staff disclosures, please see the Accreditation information section at www.pharmacist.com/education.

The content of this session was developed by the Federal Contracts and Grants group, which is managed by the American Pharmacists Association. No commercial support was used to develop this activity.

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ACPE Information

The American Pharmacists Association is accredited by the Accreditation Council for Pharmacy Education (ACPE) as a provider of continuing pharmacy education (CPE). This knowledge based activity 340B Compliance Improvement Series: ‐Education and Training, is approved for 1.0 contact hours of CPE credit (0.10 CEUs). The ACPE Universal Activity Number (UAN) assigned to this activity is 0202-0000-16-086-L04-P/T. The target audience is pharmacists and pharmacy technicians and there is no fee required for this activity.

Initial release date: January 13, 2016

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A82WCPE credit is only available for the live webinar. You MUST be registered through the registration page to obtain credit. The registration link will close today at 4:00pm Eastern.

To obtain CPE credit for this activity, you are required to actively participate in this activity and complete an evaluation. The attendance code above is needed to access and complete the evaluation.

Your CPE must be filed by Friday 2/12/16 at 11:59 Eastern Time in order to receive credit. The attendance code expires on this date and no CPE will be granted after this time.

ACPE Credit

Deborah BraffordSenior Director - Business Operations & Education

Federal Contracts and GrantsAPhA

Diane Martin, RPhAssociate Vice President, Pharmacy Operations

Greater Lawrence Family Health Center***

Heidi Larson, PharmDPharmacy Business and Revenue Manager

Hennepin County Medical Center*

Speakers

*Peer-to-Peer Recognized Site **APhA Federal Contracts & Grants Consultant ***APhA Federal Contracts & Grants Consultant and Former Peer-to-Peer Recognized Site

Anne Marie Kondic, PharmDEducation Specialist

Federal Contracts and GrantsAPhA**

Zandra Glenn, PharmDSubject Matter Expert

Federal Contracts and Grants APhA**

Faculty & Host Peers & Subject Matter Experts

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Robert Butcher, RPhChief Pharmacy Officer

AccessHealth*

Tell Us a Little About Yourselves

Webinar Polling Question:

How many people from your organization are participating in today’s webinar?

Select One• 1 Only me • 2 - 3 people • 4 - 5 people • More than 5 people

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Learning Objectives

At the completion of this activity, participants will be able to:

• Identify the minimum 340B knowledge for organizational staff members and leaders

• Identify gaps in staff knowledge and skill related to the 340B Program

• Describe mechanisms and expectations for staff to attain and maintain their 340B knowledge and skills

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Session Organization

• Brief recap of the Compliance Improvement Webinar Series

• Second Strategic Aim: Education and Training

• Peer Examples of application of Compliance Action Items

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Compliance Improvement Webinar Series

Date Topic

November 18, 2015 Leadership Commitment

December 9, 2015 Open Office: Leadership Commitment

January 13, 2016 Education and Training

January 27, 2016 Open Office: Education and Training

February 10, 2016 Integrated 340B Systems

February 24, 2016 Open Office: Integrated 340B Systems

March 9, 2016 Measurable Improvement

March 23, 2016 Open Office: Measurable Improvement

Purpose:

• Provides guidance in establishing an organizational infrastructure

• Discussions with Peers on how to create a culture that promotes continuous improvements

• Sharing of demonstrated performance improvement concepts and action steps

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Compliance Improvement Guide

• Developed by the Peer-to-Peer Program

• Navigate through a quality improvement process

• Transform organizational culture and practices

• “How to” establish an organizational structure to achieve 340B compliance

• Download the guide here: http://p2pcomplianceguide.com/latest.aspx

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Compliance Improvement Guide:Self-Assessments C - J

Also included in the Compliance Improvement Guide are self-assessments for each of the 8 areas of knowledge and competency:

• Program Background• Audit Preparedness• Contract Pharmacy• Eligibility/Database• Diversion• Duplicate Discount• Inventory• Prime Vendor Program

To review the list of proficiencies for each category, refer to the self-assessment

appendices C through J in the Compliance Improvement Guide

http://p2pcomplianceguide.com/latest.aspx

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Compliance Improvement Model Links

•https://www.brainshark.com/aphanet/340BCompliance

Introductory Video

•http://p2pcomplianceguide.com/latest.aspx

Compliance Improvement Guide

•http://complianceassessmentA.com/form.aspx 340B Compliance Rapid Self-Assessment – Appendix A

•http://complianceassessmentB.com/form.aspx

340B Compliance Culture Self-Assessment – Appendix B

•Pages 29-39 of Guide•http://p2pcomplianceguide.com/latest.aspx

340B Proficiency Self-Assessments C-J

•http://www.hrsa.gov/opa/peertopeer/webinars.html

Register Now!

Tell Us a Little About Yourselves

Webinar Polling Question:

Which of the Compliance Improvement Resources have you already accessed?

Select All That Apply• Introductory video for the Compliance Improvement Model• Compliance Improvement Guide• Various assessment forms• Webinar #1: Nov 18 – Leadership Commitment• Open Office #1: Dec 9 – Leadership Commitment

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Compliance Improvement Model

Leadership Commitment

Education and Training

Integrated 340B Systems

Measurable Improvement

Education and Training Improvement Concepts1. Staff Knowledge

Requirements2. 340B Knowledge Self-

Assessment3. Continuous Learning

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Peer Panel

Diane Martin, RPhAssociate Vice President, Pharmacy Operations

Greater Lawrence Family Health Center

Heidi Larson, PharmDPharmacy Business and Revenue Manager

Hennepin County Medical Center

Robert ButcherChief Pharmacy Officer

AccessHealth

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Strategic Aim: Education and Training

Establish minimum 340B knowledge requirements for organizational staff members and leaders

How do you target pertinent

340B information/ education for different staff

positions?

Improvement Concept:

Interview Questions:

Which proficiency

assessments would you

recommend for different

job/positions?

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Which Proficiency Assessments Would You Recommend for Different Job/Positions?

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Which Proficiency Assessments Would You Recommend for Different Job/Positions?

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Action Items: Staff Knowledge Requirements

Action items for Staff Knowledge

Requirementsare located on page 14

of the Compliance Improvement

Guide

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Action Items: 340B Knowledge Self-Assessment

E4. Establish expectations that 340B education and

competency is an ongoing process requiring regular updating and verification

E2. Determine which education knowledge assessment areas

relate to each group

E1. Identify all individuals that belong to the following groups: • Organizational leaders that need to understand how the 340B

program impacts organizational mission, financial goals, legal/regulatory requirements, and risk management

• Operational management staff that have responsibility for establishing and maintaining processes related to 340B drug procurement, inventory management, patient eligibility, and billing

• Departmental leaders that have responsibility for provider and staff recruitment and performance

• Staff (including students, temporary, and as-needed personnel) that must carry out policies and procedures at the frontline and patient engagement level

• Providers and organizations at access points served by eligible patients

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Strategic Aim: Education and Training

Identify gaps in staff knowledge and skills related to the 340B Program

How do you assess if your staff has the minimum

knowledge requirements set by your organization?

Improvement Concept:

Interview Questions:

How would you use the compliance assessments to identify people in your

organization who need additional 340B

education?

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How Do You Assess if Your Staff Has the Minimum Knowledge Requirements Set by Your Organization?

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Strategic Aim: Education and Training

Identify gaps in staff knowledge and skills related to the 340B Program

How do you assess if your staff has the minimum

knowledge requirements set by your organization?

Improvement Concept:

Interview Questions:

How would you use the compliance assessments to identify people in your

organization who need additional 340B

education?

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Compliance Assessment vs. Proficiency Assessment

Compliance Assessments:• Appendix A & Appendix B in the

Guide (pg. 26-28)

Proficiency Assessments:• Appendix C-J in the Guide (pg. 29-39)

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Action Items: 340B Knowledge Self-Assessment

Action items for 340B Knowledge Self-

Assessmentare located on page 14

of the Compliance Improvement

Guide

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Action Items: 340B Knowledge Self-Assessment

F1. Have every person identified in

improvement Concept E complete the 340B knowledge

self –assessment areas that are

relevant to his or her group

F2. Compile results of all 340B knowledge self-assessments to identify aggregate knowledge gaps of

each group and individual staff

members

F3. Utilize audit findings to isolate and

close specific departmental, job category, and staff

knowledge gaps

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Strategic Aim: Education and Training

If an organization was beginning this

process and wanted to start an

organization-wide education strategy,

what do you recommend should be their first step?

Establish mechanisms and expectations for staff to develop and maintain 340B knowledge and skills

Action Item: “Develop and implement an

organization-wide education and

training strategy.” Is this something

that you have done? How?

Improvement Concept:

Interview Questions:

How do you use your

policies and procedures to ensure

appropriate 340B

education?

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Action Items: Continuous Learning

Action items for Continuous Learning

are located on page 14 of the

Compliance Improvement

Guide

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Action Items: Continuous Learning

G4. Integrate 340B education and training in

new staff orientation processes, performance

evaluations, and employee accountability

requirements

G6. Identify and recommend that staff

view and complete pertinent education offerings available

through the 340B Prime Vendor Program managed by Apexus and the 340B

University

G1. Develop and implement an

organization-wide education and training

strategy to address knowledge gaps identified

in the self-assessment

G2. Establish a convenient mechanism for staff to

access and complete the necessary 340B education

and training resources

G3. Create a system to monitor and verify that

staff acquire and maintain the 340B knowledge and skills as specified in their

position description

Group Activity

Webinar Polling Question:

Which of the following will you do next week to improve your organization’s 340B education and training program?

Select All That Apply• Review proficiency self assessments • Evaluate organization’s policies and procedures to include additional

educational opportunities• Work to establish minimum 340B requirements for each job description• Other (Please provide additional items in the second poll box)

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CPE Self Assessment Question

Webinar Polling Question:

Which of the following is incorrect:

Select One1) Minimum 340B knowledge requirements should be tailored to different departmental or staff

member needs based on 340B roles and responsibilities.2) Customized or targeted 340B training and education is likely to increase total individual training

time and increase knowledge retention.3) Staff 340B knowledge gaps can be assessed using the topic areas defined in the 340B Compliance

Guide Proficiency Self Assessments.4) One mechanism to attain initial 340B knowledge and skills is to incorporate a

mandatory training session during new employee orientation.5) Covered entities should define their 340B training and education expectations and requirements

within organization policies and procedures.32

How to Claim CPE Credit

A82WTo obtain CPE credit for this activity, go to:• http://www.pharmacist.com/live-activities • Login• Click “claim credit” or “add to cart”• “Enroll” in the activity • Complete the assessment and evaluation

Your CPE must be filed by Friday 2/12/16 at 11:59 Eastern Time in order to receive credit.

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Open Office

Still have questions?

Join the webinar speakers on January 27, 2016 at 2pm ET

Questions for the Open Office session will be from:

Participants must submit question(s) by January 15, 2016

Register Today to join this interactive discussion! 34

Open Office registrationOverflow of questions

from this webinarWebinar satisfaction

surveyQuestions during Q/A

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Additional Events & Resources

TrainingWebinars

• Prior Webinars – Listed on the OPA Website• Upcoming – February 10, 2016 2pm ET

340B Compliance Improvement Webinar Series: Integrated 340B Systems

340B University™• January 25/26 – Grapevine, TX• February 16/17 – San Diego, CA• Register• 340B University OnDemand™• More Information -

ApexusAnwers@340BPVP.com

Communications

Monthly Update• Important Peer-to-Peer communications the

1st week of the month• Sign up today!

LinkedIn• Join the discussion on the group page

340B Resource Network

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Compliance Improvement Model Links

•https://www.brainshark.com/aphanet/340BCompliance

Introductory Video

•http://p2pcomplianceguide.com/latest.aspx

Compliance Improvement Guide

•http://complianceassessmentA.com/form.aspx 340B Compliance Rapid Self-Assessment – Appendix A

•http://complianceassessmentB.com/form.aspx

340B Compliance Culture Self-Assessment – Appendix B

•Pages 29-39 of Guide•http://p2pcomplianceguide.com/latest.aspx

340B Proficiency Self-Assessments C-J

•http://www.hrsa.gov/opa/peertopeer/webinars.html

Register Now!

Contact Information

340B Program • www.hrsa.gov/opa

340B Peer-to-Peer Program

• http://www.hrsa.gov/opa/peertopeer/index.html

Apexus Answers 340B Technical

Assistance

• 1-888-340-2787 • ApexusAnswers@340Bpvp.com• https://www.340bpvp.com

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Solutions for 340B Entities

CONTRACTING

340B Prime Vendor Program

EDUCATION

340B University™ & 340B OnDemand

ASSISTANCE

Apexus Answers Call Center

www.340bPVP.com (888) 340-BPVPApexusAnswers@340bPVP.com

www.340Bpvp.com/340B-University