Beeman 's Pharmacy : 340b Policy And Procedure

Roger Turner, an agent for Optum Health Behavioral Program (OHBP) alleges Dr. Arturo Taca over utilizes drug screen services, opened a substance abuse rehab facility under a different TIN, known as “Insynergy” which operates as cash only or by providing “member’s” financing in the form of signing them up for credit cards. Mr. Turner also alleges Dr. Taca failed to notify OHBP of his affiliation with Insynergy, submits claims for injections for upwards of $2200 per injection as an Out of Network expense and therefore member liability, has three TIN’s operating registered for the same or similar addresses, and is not contracted by OHBP to administer injectable’s to OHBP members, however an audit shows 11 members received services (billed as injectable) from Insynergy.

As the brand manager for Allround cold medicine, there were many decisions regarding product formulation, strategy, line extensions and product launches over the company’s last 10 periods. The brand was focused on remaining a profitable, mature product family within the cold medicine category, but also maintaining a premium brand image.

Phansalkar, S., Her, Q. L., Tucker, A. D., Filiz, E., Schnipper, J., Getty, G., & Bates, D. W. (2015). Impact of incorporating pharmacy claims data into electronic medication reconciliation. American Journal Of Health-System Pharmacy, 72(3), 212-217 6p. doi:10.2146/ajhp140082

Erica Lindsay, PharmD, MBA, JD, is a health care attorney practicing in the greater Chicagoland area. She has worked in pharmacy management and compliance for more than 15 years. Dr. Lindsay consults clients through complex pharmacy regulations and guidelines, including 340B, Medicare and Medicaid billing, and HIPAA compliance. She is on faculty of PharmCon providing instruction on pharmacy legal and regulatory issues. Dr. Lindsay is active in various organizations including the American Bar Association where she is Vice of the Nursing and Allied Healthcare Professionals Task Force and members of the Health Care Compliance Association, Cook County Bar Association, and the Chicago Bar Association. She is a graduate of Florida A&M University

When doctors prescribe medication for their patients, a local retail pharmacy is most likely to be utilized to fill the order. However, there is a growing population of older Americans that are no longer able to live independently and must reside in nursing homes or assisted living facilities. In order for this vulnerable population to receive their medications, a different kind of pharmacy is needed, these are known as LTC, long term care pharmacies. Within these specialized pharmacies there are highly trained employees called CPhTs, certified pharmacy technicians who are overseen by state licensed

Although the Stark law does not apply to ASCs, the federal Anti-kickback Statute does apply. The Anti-Kickback statute prohibits any person from “knowingly and willfully” providing any remuneration to induce referrals, or in exchange for referrals, of federal health care program patients or business.2 Accordingly, the Anti-kickback Statute applies to any physician-owned ASC that treats federal health care program patients (including Medicare and Medicaid), in that the potential return on investment, arguably, could be viewed as an inducement for physician investors to refer to the ASC. However, there is an ASC “safe harbor” under the Anti-kickback Statute, which protects various types of physician-owned ASCs as well as hospital/physician ASC

It is composed of actively practicing physicians, other prescribers, pharmacists, nurses, administrators, quality improvement managers, and other health care professionals and staff who participate in the medication-use process. The P&T committee should be responsible for overseeing policies and procedures related to all aspects of medication use within an institution. The P&T committee is responsible to the medical staff as a whole, and its recommendations are subject to approval by the organized medical staff as well as the administrative approval process. The P&T committee’s organization and authority should be outlined in the organization’s medical staff bylaws, medical staff rules and regulations, and other organizational policies as appropriate. Other responsibilities of the P&T committee include medication-use evaluation (MUE), adverse-drug-event monitoring and reporting, medication-error prevention, and development of clinical care plans and guidelines. The hospital’s internal policies follow all national standards for how the P&T committee should

PMP data provides insight into questionable activity, either by physicians, patients whom “physician shop”, or prescription fraud.1 This database is unique in that it compiles information about the physician that wrote the medication, the pharmacy that dispensed it, the patient receiving the medication, and payment method into a central

Medicare, one of the greatest purchasing clients in the medication industry, is not lawfully allowed to bargain first hand with companies for lower medication costs or best possible price. (Kounang, 2015)

The SCHC addressed meaningful use by recording patient demographics, maintaining an active medication lists and incorporating clinical lab test results into the HER, as apart of their meaningful use objectives. For recording patient demographics, they maintained data for accurate billing and ensured that the practice workflow was adjusted to capture all of the necessary patient data. They addressed active medication lists by following the requirements for e-prescribing. Patients were able to review their active medication list during their visit. Changes to the medication list were reviewed with the nurse and adjusted within the EHR system by the doctor. They communicated information for the care coordination process by making test results efficient and safe to access. Physicians were able to make real time decisions when they receive the test results from LabCorp, Quest, and other health

These include one of the most important being the Health Insurance Portability and Accountability Act or HIPAA of 1996. This act ensures that patient privacy and security standards are in place for distribution and access of that information. All employees, not just those in the pharmacy must do their best to protect their patient’s information. HIPAA information is available to all patients at their request. There are many other federal regulations that the pharmacy must adhere to that are established by the U.S. Food & Drug Administration. Pharmacists must adhere to all laws and regulations by the state of South Carolina and the Federal government in the dispensing and selling of medication and controlled substances. The state law takes precedence over all other federal

The Anti-Kickback Law was created to protect patients and the federal health care programs from fraud and abuse by preventing exchanges of “anything of value” used to encourage physician referrals. OIG defines anything of value as “cash, such as free rent, expensive hotel stays and meals, and excessive compensation for medical directorships or consultancies” (“A Roadmap for New Physicians: Fraud & Abuse Laws”). In addition, OIG expressed that kickbacks can lead to “overutilization, increase in program costs, corruption of medical decision making, patient steering, and unfair competition” (“Federal Anti-Kickback Law and Regulatory Safe Harbors”). Consequently, OIG implemented the statute to deter or prevent pharmaceutical and device companies

These programs can be successful when applied but without a physician being required to participate they can be unuseful as it leads to lack of accurate information for public health records. Doctors and pharmacist should both have a legal obligation to check a drug monitoring database and participate further in drug monitoring programs. Doctors and pharmacies should also be investigated for prescribing large quantity of prescription medication resulting in legal action if perhaps they are found guilty of overprescribing. With legislators onboard to curb the misuse of prescription medication this problem can finally be

Electronic-prescribing, often referred to as e-prescribing, is a fairly new, innovative way for physicians and other medical personnel to prescribe medications and keep track of patients’ medical history. Not only has e-prescribing enabled prescribers to electronically send a prescription to the patients’ pharmacy of choice, in the short amount of time it has been available, it has significantly reduced health care costs, not only for the patient, but for the medical facilities as well. In 2003, e-prescribing was included in the Medicare Modernization Act (MMA) which jumpstarted the role of e-prescribing in healthcare. It has proven to significantly reduce the yearly number medication errors and prescription fraud, and its widespread

Some organizations are subject Group Purchasing Organi- zation (GPO) Prohibition and Orphan Drug Exclusions. DSHs and CAHs subject to GPO Prohibition means that in order to participate in the 340B program, these entities cannot obtain outpatients drugs through GPOs.4 This is where some institutions use split billing software with 3 different accounts: GPO inpatient eligible account, 340B eligible outpatient account, and non-GPO/WAC (wholesaler acquisition account). Also, Orphan Drug Ex- clusion means organizations such as SCHs and CANs can’t obtain designated orphan drugs at 340B prices. However, these hospitals can purchase orphan drugs at a discount through the 340B program if they are used to treat non-orphan