Stewardship Principles Implementation for 340B Program Success

AHA 340B Advocacy Alliance Webinar: Good Stewardship Principles Implementation

Agenda AHA 340B Stewardship Principles o Review Lessons from the Field: o University of California Health System o Johns Hopkins Medicine Permit covered entities Permit covered entities to stretch scarce Federal resources as far as possible, Federal resources as far as possible, reaching more eligible patients and reaching more eligible patients and providing more comprehensive services. providing more comprehensive services. to stretch scarce o Providence St. Joseph Health Questions? H.R. Rep. No. 102-384(II), at 12 (1992)

AHA 340B Good Stewardship Principles Communicate the Value of the 340B Program Disclose Hospital s 340B Estimated Savings Continue Rigorous Internal Oversight

BE A GOOD STEWARD OF 340B Julie Clements, JD, MPP Director of Health and Clinical Affairs Federal Governmental Relations University of California Health System Julie.Clements@ucdc.edu/(202)-974-6309

Communicate Your 340B Discounts Value. Convene your Pharmacy Chiefs, 340B administrators, and finance leadership. Document how you utilize the savings accrued from your 340B discount to provide medical services to underserved patients. Emphasize the specific services provided and the vulnerable populations helped. Identify services that could be undermined or eliminated should the scope of the 340B discount be narrowed. Publish your 340B narrative on your hospital website under an area, such as Serving the Community, that policymakers and patients can easily access.

Calculate Your 340B Savings Adopt the standardized approach, known as the Savings Calculator, for calculating your hospitals 340B savings. Work with your hospitals finance leads to ensure you re correctly accounting for the dollars your hospitals avoid spending on outpatient drugs on the 340B formulary, as well as the dollars your hospitals receive through contract pharmacy arrangements. Derive a 340B savings number for your hospitals and publish it in the website narrative detailing your hospitals unique 340B story.

Show 340B Value in Context * GRAPH REPRESENTS IN MILLIONS OF $ ANNUAL SPEND ON DRUGS VERSUS IN MILLIONS OF $ IN ANNUAL 340B BENEFITS. Annual Drug Spend Vs. 340B Benefit for Hospitals 180 160 140 120 100 80 60 40 20 0 Hospital 1 Hospital 2 Hospital 3 Hospital 4 Drug Spend 340B Savings

Rigorous, Internal Oversight Convene your pharmacy, compliance, and finance leadership to assess what voluntary steps you can take to implement a dependable framework for assuring 340B compliance. WHAT CAN YOU DO??? Hire an external auditor annually to examine your 340B program, including contracts with software vendors and contract pharmacy arrangement contracts. Sponsor continuing education forums for pharmacy, finance, and compliance personnel on the do s and don ts of the 340B program. Inventory and document internally all ways in which 340B benefits are being used to help patients. Evaluate the feasibility of using 340B savings to furnish a drug discount program that will benefit underserved patients who need assistance affording their outpatient drugs, and do so in compliance with the hospitals Financial Assistance Policies and CMS regulations against inducements.

Putting into Practice the Good Stewardship Principles UC Health convened two teams to put into effect the AHA s 340B Good Stewardship Principles: A finance team led by the CFO at UC Davis Health to assist with using the Savings Calculator to devise each medical center s savings number; A pharmacy team led by the CPO at UC Irvine Health to help individual pharmacy chiefs and 340B administrators write their 340B stories.

Published 340B Narratives UC Davis Health- https://health.ucdavis.edu/newsroom/public- reporting/340b-program.html UC Irvine Health- https://www.ucihealth.org/340b-program UCLA Health- https://www.uclahealth.org/340b-program UC San Diego Health- https://health.ucsd.edu/about/Documents/Val ue-of-340B-Program-UCSD.pdf UCSF Health- https://www.ucsfhealth.org/about/340b- program/

Melisa Lindamood Director, Federal Affairs

U.S. House Energy and Commerce U.S. House Energy and Commerce Oversight and Investigations Subcommittee Examining How Covered Entities Utilize the 340B Drug Pricing Program October 11, 2017 Witnesses: Sue Veer, President, Carolina Health Centers Mike Gifford, CEO, AIDS Resource Center Ron Paulus, CEO, Mission Health Charles Reuland, COO, The Johns Hopkins Hospital Shannon Banna, Controller, Northside Hospital

www.hopkinsmedicine.org/jhh/340B

Jacquelyn Bombard Director, Federal Relations

Compelled by our heritage What concerns the poor and vulnerable is always our affair 16

Our advocacy to preserve the program 17

Our advocacy to preserve the program 340B helps save lives The benefits of having an on-site pharmacist has been significant for patients in some cases even lifesaving, such as an elderly cancer patient who needed a common antifungal medication. The patient was progressing well on oral chemotherapy and, before prescribing the antifungal for a co-occurring problem, her oncologist consulted with the oncology pharmacist funded by 340B. The pharmacist flagged a dangerous interaction likely to cause severe toxicity and a heart attack, then advised on alternate medications. The changes were complex, so the pharmacist provided guidance and counselling to the patient, who has progressed well and is grateful for the extra care and support. 18

Our advocacy to preserve the program Helping seniors afford necessary medications An elderly patient with low-income recently needed Enoxaparin, an anticoagulant medication. When the insurance company would not pay the full amount for the treatment, they faced a $400 bill and considered going without the medication. Going without this prescription could have led to a blood clot, pulmonary embolism, heart attack, or even death. Thanks to the 340B program, they were able to purchase the necessary medication for $80. 19

Our advocacy to preserve the program Access to lifesaving treatment Savings from 340B have helped a patient with a rare enzyme deficiency disease get more convenient access to an expensive enzyme replacement therapy at a more affordable cost. The patient was driving about 100 miles round trip every two weeks to receive his treatment. Now, he receives his therapy closer to home at Providence St. Peter s Outpatient Infusion Department, at a lower cost. 20

In addition to our traditional advocacy Grassroots mobilization: PSJH has deployed a caregiver grassroots platform where caregivers can send letters to members of Congress urging them to preserve the program. Traditional media: PSJH s system and regional leadership have interviewed with local and national media outlets highlighting the value of the program. Social media: Using social media to complement our traditional media strategy. Partnerships: Working closely with the AHA to advance our proactive 340B stewardship principals. Also partnering with other national and state stakeholders to advocate for productive solutions to reform the program. 21

QUESTIONS?