Under the general direction of the Manager of Pharmacy Services and working directly with providers, support staff, and patients, the 340B Pharmacist will perform the essential duties and responsibilities outline below:
ESSENTIAL DUTIES AND RESPONSIBILITIES
1. 340B Program Coordination: • Serves as the institutional “compliance expert or authority” on 340B regarding program details, policies, and procedures of the virtual inventory processes required for contract pharmacy relationships.
• Serves as primary internal liaison to key stakeholders to help ensure appropriate utilization of the 340B Program and compliance with all program requirements.
• Provides oversight and leadership from the Pharmacy Services Department for the 340B Program. Helps lead and assist the organization’s 340B oversight team, which includes representation from pharmacy, medical, nursing, finance, and senior administration.
• Provides expertise with the 340B Program to staff and participants regarding ongoing compliance. • Develops and maintains external relationships (wholesalers, manufacturers, contract pharmacies, pharmacy benefits managers (PBMs), and third-party administrator (TPA) vendors) as needed.
2. Policy and Procedure Development: • Ensures that policies and procedures are developed and implemented according to organizational, regional, national, state, and federal requirements and guidelines. • Assists organizational leadership to develop a regular compliance audit program. • Contributes processes and materials to promote programs or support the goals of the department and organization.
3. Education: • Provides ongoing training, education, and communication required for the 340B Program at the organization.
• 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. Establishes a clear way for staff to communicate concerns to the coordinator.
• Provides regular education to staff on policies and procedures related to 340B compliance.
4. Rules/Guidance Surveillance: • Monitors and assesses 340B guidance and/or rule changes, including, but not limited to, HRSA/OPA rules and Medicaid changes to ensures that the 340B pharmacy program is continuously compliant with 340B federal regulations.
• Attends regular 340B trainings and shares lessons and hot topics with staff. • 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.
• Collaborates with the Prime Vendor Program, pharmacy leadership, and other 340B institutions to determine the most appropriate use of the 340B Program staff.
• Develops knowledge and maintains awareness of current regulations, trends, and issues pertaining to the 340B Program.
• Responsible for ensuring that the annual HRSA re-certification 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 site within the allowable time frame.
6. Self-Audits: • Develops, executes, and documents self-audits of the 340B process. Coordinates and ensures remediation of findings. • Is responsible for the oversight of required 340B audits, both internally and externally. • Ensures compliance with all aspects of the 340B Program and implements all applicable aspects of HRSA’s Office of Pharmacy Affairs guidance, as well as organizational policies and procedures. • Conducts and/or coordinates an annual audit of all contract pharmacies. Documents results and follow- up on any findings. • Routinely reviews data and related reports from all points of service at which 340B participation occurs to ensure that policies and procedures are followed, entity eligibility requirements are met, and all patients meet patient definition requirements. • Responsible for managing and troubleshooting pharmacy billing issues and ensuring that adequate systems checks are reviewed to prevent billing issues. • 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, where appropriate, to validate internal processes. • Monitors 340B compliance within workflow processes. • Responsible for the day-to-day management, compliance review, and operations of clinic- administered medications in eligible locations, outpatient prescriptions fulfilled by an owned pharmacy, and outpatient prescriptions fulfilled by a contract 340B pharmacy. • Conducts periodic audits of all 340B-eligible locations to verify adherence with the 340B Program guidelines and policies.
7. External Audits: • Serves as the point person and coordinator for all external audits. Coordinates all requests and responses. Maintains a current state of “audit readiness.” • Works with medical auditors on third-party payer audits to ensure coordination of efforts and maximum collection. • Provides oversight for all audits performed by independent external auditors. • Coordinates external compliance assessments with outside firms, where appropriate, to validate internal processes.
8. 340B Contract Management: • Reviews and negotiates any new 340B contracts. Maintains all 340B contracts. • Manages relationships, billing services, and compliance with contracted 340B pharmacies. • Evaluates all current and future contract pharmacy opportunities, including contract language, fee structure, data setup, and internal and independent external auditing. • Works directly with manufacturers, as well as through GPO and peer professional relationships, to determine companies that are contracting with inpatient facilities to offer 340B or equivalent pricing and develops strategies to maximize such participation.
9. Program Enhancement/Optimization: • Assesses opportunities for cost savings and business improvements in 340B contract pharmacy utilization. • Participates in projects, councils, and special initiatives related to 340B, compliance, auditing functions, vendor selection, and medication management. • Provides input and implements business plans in coordination with the organization’s pharmacy leadership for organization facilities to help use 340B savings to expand and improve care provided to underserved and vulnerable populations; assists facilities to prioritize and implement outpatient program development and contract pharmacy agreements related to 340B; and assists the organization’s leadership with program development and optimization.
10. Reporting: • 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 and administration. • Ensures that reporting meets organizational, regional, national, state, and federal requirements/guidelines. • Ensures appropriate documentation and audit trail across areas of responsibility.
11. Purchasing/Inventory Oversight: • Monitors purchasing records for each 340B participant; clearly documents utilization, savings, problem areas, and exceptions or discrepancies. Relays results to pharmacy leadership and administration. • Monitors for 340B pricing exclusions or shortages and establishes appropriate alternative products that are included when possible, including work with medical staff 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. • Work with procurement team to optimize purchasing of supplies and medications from the 340B program. • Ensures compliance with regulations related to 340B purchasing.
12. Clinical Pharmacy Support (secondary role to support primary clinical pharmacist as needed) • Assess the status of the patient’s health problems and determine whether the prescribed medications are optimally meeting the patient’s needs and goals of care. • Evaluate the appropriateness and effectiveness of the patient’s medications. • Recognize untreated health problems that could be improved or resolved with appropriate medication therapy. • Follow the patient’s progress to determine the effects of the patient’s medications on his or her health. • Consult with the patient’s providers in selecting the medication therapy that best meets the patient’s needs and contributes effectively to the overall therapy goals. • Advise the patient on proper medication use. • Apply specialized knowledge of the scientific and clinical use of medications, including medication action, dosing, adverse effects, and drug interactions, in performing their patient care activities in collaboration with other members of the health care team. • Support the health care team’s efforts to educate the patient on other important steps to improve or maintain health, such as exercise, diet, and preventive steps like immunization.
13. Provide a consistent process of patient care that ensures the appropriateness, effectiveness and safety. •Education and Experience *
_ _ It is necessary to have a BS Pharmacy Degree or a Doctor Pharmacy Degree and at least one year of pharmacy practice experience. One year of experience with the 340B program is required. Completion of Apexus 340B University and/or Advanced 340B Operations Certificate Program may be acceptable in lieu of 340B work experience. Degrees in business administration, healthcare administration, healthcare management, or healthcare informatics may also be acceptable in lieu of 340B work experience.
Certifications in different areas of Pharmacy and an accredited residence program are a plus.
_Knowledge, Skills and Abilities _ _ _ Personal abilities such as communication (both oral and written), deep knowledge of drugs, medical procedures and therapies, diagnosis and disease states, and some pharmaco-kinetics.
Skills in working with technical automated equipment and information systems are an added value.
IV. Language Skills: • Ability to read and interpret documents such as government regulations and guidelines, patient records, operating and maintenance instructions, procedure manuals, etc. • Ability to write at a minimal level of competence, including internal reports and memoranda. • Ability to communicate with diverse groups of people to include staff and providers and patients. • Ability to communicate effectively with patients and their families to make their visit a pleasant experience. • Sensitivity to the multicultural nature of the service area population and may be required to communicate in another language.