The 340B Program Coordinator, in conjunction with designated system leadership, is responsible for providing ongoing program development and support of the 340B program. Serves as primary internal and external program coordinator and liaison for all 340B-related matters. These activities involve reporting, system and process evaluation, formulation of recommendations and initiatives, coordination and implementation of intervention strategies, and monitoring of activities related to Northern Arizona Healthcare's participation in the 340B program. Provides oversight and leadership for the 340B program. Leads and assists the organization’s 340B oversight team, which will include representation from pharmacy, legal, compliance, finance, and senior administration. 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. 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. This position's work location is remote.
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340B Program Coordination * Serves as the compliance expert or authority on 340B across the System. * Serves as primary internal liaison to key stakeholders to help ensure appropriate utilization of the 340B program and compliance with all program requirements. * Develops and maintains internal relationships (accounting, legal) and external relationships (wholesalers, manufacturers, contract pharmacies, split-billing software vendors, employee benefit pharmacy benefits managers (PBMs), and third-party administrator (TPA) vendors) as needed. * Actively engages with senior leadership and participates in decision-making processes related to the implementation of new 340B processes. |
Policy and Procedure Development * Ensures that policies and procedures are developed and implemented according to organizational, regional, national, state, and federal requirements. * Assists organizational leadership to develop a regular compliance audit program. |
Education * Provides ongoing training, education, and communication required for the 340B program at the organization. * Manages health system education, training, awareness, and customer service for all 340B covered entities. * 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. |
Rules/Guidance Surveillance * Monitors and assesses 340B guidance and or rule changes. Attends regular 340B trainings and shares learnings 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. * Ensures that the 340B pharmacy program is continuously compliant with 340B federal regulations. * Provides expertise on all 340B program legislation and policy changes from HRSA and OPA, informing and collaborating with legal and compliance teams. |
Registration/Recertification * Responsible for ensuring that the annual HRSA recertification is completed within the allowable time frame. * Responsible for ensuring that the HRSA 340B Database is accurate for all organization entities. * Responsible for ensuring registration of any new child site or contract pharmacy within the allowable time frame. |
Audits/Reporting * Develops, executes, and documents routine self-audits of the 340B process. Coordinates and ensures remediation of findings. * Reviews and monitors all points of service where 340B participation occurs to ensure policy and procedure compliance, covered entity eligibility, and “covered patient” eligibility. * 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. * Responsible for managing and troubleshooting pharmacy billing issues and ensuring that adequate systems checks are reviewed to prevent billing issues. * Serves as the point person and coordinator for all audits. Coordinates all requests and responses. Maintains a current state of “audit readiness.” * Routinely monitors purchasing records along with 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. |
Purchasing/Inventory Oversight * Monitors for 340B pricing exclusions or shortages and establishes appropriate alternative products that are included where possible, including work with medical staff and formulary to ensure proper position and related use. * Tracks, trends, and reports 340B pharmaceutical sales and purchases data to ensure provider/physician and patient eligibility. * Establishes a routine approach to updating the CDM/crosswalk for new products and product changes to ensure both the accuracy of the utilization report and the efficiency and accuracy of the charge process. |
Compliance/Safety * Responsible for reporting any safety-related incident in a timely fashion through the Midas/RDE tool; attends all safety-related training programs; performs work in a safe manner; monitors work environment for possible safety issues and ensures others are also performing work in a safe manner. * Stays current and complies with state and federal regulations/statutes and company policies that impact the employee's area of responsibility. * If required for the position, ensures all certifications and/or licenses are up-to-date and valid prior to expiration dates. * Completes all company mandatory modules and required job-specific training in the specified time frame. |
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