Complete Guide to 340B Provider Audits and Analysis

Audit Analysis 7 6 5 4 3 2 1 0 Accumulator Discrepancies Over-purchase Diversion Suspicious Activity GPO 340B WAC 340Bsure Make 340B audits as automatic and complete as the 340B Providers who do the splitting. Don t assume, BE SURE!

Who We Are Stuart Murray Created very first 340B Splitting application, Integrated Healthcare Systems, which became Talyst and then Verity Solutions. Worked there for twenty years. Performed numerous 340B Hospital Audits. Worked for RxStrategies for four years. Created CardinalAssist (Pyxis small packaging program) for Cardinal Health. Created GrassRoots Manager and sold it to AFLCIO and AFSCME. Carla Corkern CEO of Talyst (340B Splitting and Medical Automation). Experience in many technology markets: Healthcare, Automation, SAAS Platforms for Supply Chain and Healthcare. Enterprise infrastructure & applications, EAI, corporate portals, knowledge management. Content management, search technology, XML infrastructure technology. Security/user management, wireless/mobile apps, networking, groupware. Personal productivity applications.

Who We Are Lynn Zimmerman Certified Fraud Examiner. Performed numerous 340B Hospital Audits. Tamaira Murray Audit Manager for Talyst. Performed hundreds of 340B Hospital Audits.

Main Problems With Audits 1. Complicated and time consuming. 2. Limited number of items that you can audit due to problem nbr 1. 3. Lack of transparency. Were dispenses reprocessed later with different mappings and multipliers? What happened to the original data? Is there a record of it? Were any records deleted? Changed? Is there a record of the changes to the data after reprocessing (before and after snapshots)? What changed? How much? Did anything go negative (and what was done about it)?

How would you like to Compare ALL dispenses for a time frame against: An extract of a hospital s EMR to verify that all 340B (and GPO) dispenses can be verified. Not just a random few. A comparison of the raw dispenses against an extraction of the dispenses from a hospital s 340B provider? Our Accumulation totals vs Theirs. A check to see which Accumulations are NEGATIVE (showing over-purchase). Compare all Orphan Drugs to hospital INVOICES to see which items were purchased on 340B. Compare hospital s Pure 340B list to see if any purchased on GPO. Compare hospitals Pure GPO list to see if any purchased on 340B.

Catch Double-Discounts!!! Receive a Sum Purchase Total by NDC Across Account TYPE (340B, GPO, and WAC) along with a column showing Medicaid Total Qty. If we have access to hospital Medicaid claims we can compare these against their accumulated 340B dispenses to show which items definitely received a double-discount. Imagine finding Pure 340B items (never dispensed by policy to inpatients) showing up on Medicaid claims.

How can WE do this when YOU can t? Because we have software that automates the process. YOU can t look at everything, but the software CAN. There is too much data to try and audit manually, which is why you need software that CAN process all of the data just like the 340B providers process all of the data. We can process everything with a single click of a button and receive results back on the same day (in most cases). We don t have to visit a hospital or be intrusive into their time!

What about data security? Our software and all work resides on an Azure Virtual Machine with NO ACCESS to the internet (incoming or outgoing). All connections to the Virtual Machines are made through Azure s Bastion service or RDP. Azure Bastion is a fully managed service that provides more secure and seamless Remote Desktop Protocol (RDP) and Secure Shell Protocol (SSH) access to virtual machines (VMs) without any exposure through public IP addresses. Requires an Azure account and permissions. We delete the Virtual Machine (which includes ALL data) after the audit is over! Only the spreadsheets resulting from the audits are provided to the audit requestors at the end of the process.

data security continued Files are transferred from the hospital (or 340B provider) to the Azure Virtual Machine using Files.com (HIPPA certified SFTP) Don t forget, many hospitals are already sending this data to the 340B providers, often using HTTPS, FTP, or SFTP, so they can t complain about a MORE SECURE transfer!

Spreadsheets you receive Final accumulation totals for each account (340B, GPO, WAC), sorted by accumulation total so that negative qtys will show up first and extremely high totals will show up last. Summary of Total Accumulator Qty, BY NDC ACROSS accounts (340B, GPO, WAC). Same as above with an additional column showing Medicaid Total Qty by NDC. Listing of 340B dispenses with no corresponding EMR outpatient dispense. Listing of pure340B drugs that were purchased under GPO. Listing of pureGPO drugs that were purchased under 340B. Drugs never purchased under WAC (or extremely low purchases). Listing of orphan drugs dispensed to 340B. Pure340B items that also show up on Medicaid. Optional: Comparison of our Accumulator totals vs 340B Provider s Exported Dispenses. Optional: 340B dispenses not found in hospital EMR extract.

Goal is to improve the 340B process! Improve transparency. Catch bad actors. Show hospitals how to improve their processes (they can use us for their internal audits, too). Force 340B providers to improve their own software and policies. No more deleting data. Change-records kept for all reprocessing done. Better handling\reporting on negative Accumulation. Eliminate double-discounts.

What is the COST? Ask yourself, how much is non-compliance costing YOU? Millions of dollars are being lost due to poor transparency, bad actors, bad policies, and infrequent\limited audits.