Health Resources and Services Administration
Office of Pharmacy Affairs
340B Peer-to-Peer Program
340B Compliance Improvement Series:
Education and Training
January 13, 2016
2:00-3:00 PM Eastern
*The 340B Peer-to-Peer Program operates under a Health Resources and Services Administration contract with the American Pharmacists
Association Federal Contracts and Grants. The intent of this program is for 340B Leading Practice Sites and Subject Matter Experts to share
their operational best practices and not the official policies of the Office of Pharmacy Affairs. The mention of trade names, commercial
practices, or organizations does not imply endorsement by the U.S. Government. Additionally, your practice setting may require differences to
ensure 340B program integrity and meet all state or federal requirements.
340B Webinar
Full Screen
We encourage
you to submit
questions
throughout the
presentation
through the chat
function of the
webinar.
Download
Slides
Links
Q&A – for
questions
Closed Captioning
2
Financial Disclosure
Zandra Glenn, PharmD; Anne Marie Kondic, PharmD; Deborah Brafford; Heidi Larson,
PharmD; Robert Butcher, RPh; and Diane Martin, RPh declare no conflicts of interest
or financial interests in any product or service mentioned in this activity, including
grants, employment, gifts, stock holdings, and honoraria. For complete staff
disclosures, please see the Accreditation information section
at www.pharmacist.com/education.
The content of this session was developed by the Federal Contracts and Grants group,
which is managed by the American Pharmacists Association. No commercial support
was used to develop this activity.
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ACPE Information
The American Pharmacists Association is accredited by the Accreditation Council
for Pharmacy Education (ACPE) as a provider of continuing pharmacy education
(CPE). This knowledge‐based activity 340B Compliance Improvement Series:
Education and Training, is approved for 1.0 contact hours of CPE credit (0.10
CEUs). The ACPE Universal Activity Number (UAN) assigned to this activity is 02020000-16-086-L04-P/T. The target audience is pharmacists and pharmacy
technicians and there is no fee required for this activity.
Initial release date: January 13, 2016
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ACPE Credit
A82W
CPE credit is only available for the live webinar. You MUST be registered through the
registration page to obtain credit. The registration link will close today at 4:00pm Eastern.
To obtain CPE credit for this activity, you are required to actively participate in this activity and
complete an evaluation. The attendance code above is needed to access and complete the
evaluation.
Your CPE must be filed by Friday 2/12/16 at 11:59 Eastern Time in order to receive credit.
The attendance code expires on this date and no CPE will be granted after this time.
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Speakers
Faculty & Host
Zandra Glenn, PharmD
Subject Matter Expert
Federal Contracts and Grants
APhA**
Anne Marie Kondic, PharmD
Education Specialist
Federal Contracts and Grants
APhA**
Deborah Brafford
Senior Director - Business Operations & Education
Federal Contracts and Grants
APhA
Peers & Subject Matter Experts
Heidi Larson, PharmD
Pharmacy Business and Revenue Manager
Hennepin County Medical Center*
Robert Butcher, RPh
Chief Pharmacy Officer
AccessHealth*
Diane Martin, RPh
Associate Vice President, Pharmacy Operations
Greater Lawrence Family Health Center***
*Peer-to-Peer Recognized Site
**APhA Federal Contracts & Grants Consultant
***APhA Federal Contracts & Grants Consultant and Former Peer-to-Peer Recognized Site
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Tell Us a Little About Yourselves
Webinar Polling Question:
How many people from your organization are participating in today’s webinar?
Select One
• 1 Only me
• 2 - 3 people
• 4 - 5 people
• More than 5 people
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Learning Objectives
At the completion of this activity, participants will be able to:
• Identify the minimum 340B knowledge for organizational staff members and leaders
• Identify gaps in staff knowledge and skill related to the 340B Program
• Describe mechanisms and expectations for staff to attain and maintain their 340B
knowledge and skills
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Session Organization
• Brief recap of the Compliance Improvement Webinar Series
• Second Strategic Aim: Education and Training
• Peer Examples of application of Compliance Action Items
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Compliance Improvement Webinar Series
Purpose:
• Provides guidance in establishing an
organizational infrastructure
• Discussions with Peers on how to create
a culture that promotes continuous
improvements
• Sharing of demonstrated performance
improvement concepts and action steps
Date
Topic
November 18, 2015
Leadership Commitment
December 9, 2015
Open Office: Leadership
Commitment
January 13, 2016
Education and Training
January 27, 2016
Open Office: Education and
Training
February 10, 2016
Integrated 340B Systems
February 24, 2016
Open Office: Integrated 340B
Systems
March 9, 2016
Measurable Improvement
March 23, 2016
Open Office: Measurable
Improvement
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Compliance Improvement Guide
• Developed by the Peer-to-Peer Program
• Navigate through a quality improvement process
• Transform organizational culture and practices
• “How to” establish an organizational structure to
achieve 340B compliance
• Download the guide here:
http://p2pcomplianceguide.com/latest.aspx
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Compliance Improvement Guide:
Self-Assessments C - J
Also included in the Compliance Improvement Guide are self-assessments for each of
the 8 areas of knowledge and competency:
•
•
•
•
•
•
•
•
Program Background
Audit Preparedness
Contract Pharmacy
Eligibility/Database
Diversion
Duplicate Discount
Inventory
Prime Vendor Program
To review the list of proficiencies for each
category, refer to the self-assessment
appendices C through J in the
Compliance Improvement Guide
http://p2pcomplianceguide.com/latest.aspx
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Compliance Improvement Model Links
Introductory Video
Compliance Improvement
Guide
• https://www.brainshark.com/aphanet/340BCompliance
• http://p2pcomplianceguide.com/latest.aspx
340B Compliance Rapid SelfAssessment – Appendix A
• http://complianceassessmentA.com/form.aspx
340B Compliance Culture SelfAssessment – Appendix B
• http://complianceassessmentB.com/form.aspx
340B Proficiency
Self-Assessments C-J
Register Now!
• Pages 29-39 of Guide
• http://p2pcomplianceguide.com/latest.aspx
• http://www.hrsa.gov/opa/peertopeer/webinars.html
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Tell Us a Little About Yourselves
Webinar Polling Question:
Which of the Compliance Improvement Resources have you already accessed?
Select All That Apply
• Introductory video for the Compliance Improvement Model
• Compliance Improvement Guide
• Various assessment forms
• Webinar #1: Nov 18 – Leadership Commitment
• Open Office #1: Dec 9 – Leadership Commitment
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Compliance Improvement Model
Leadership
Commitment
Education
and Training
Education and Training
Improvement Concepts
1. Staff Knowledge
Requirements
2. 340B Knowledge SelfAssessment
Integrated
340B Systems
Measurable
Improvement
3. Continuous Learning
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Peer Panel
Heidi Larson, PharmD
Robert Butcher
Diane Martin, RPh
Pharmacy Business and Revenue Manager
Hennepin County Medical Center
Chief Pharmacy Officer
AccessHealth
Associate Vice President, Pharmacy Operations
Greater Lawrence Family Health Center
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Strategic Aim: Education and Training
Improvement
Concept:
Interview
Questions:
Establish minimum 340B knowledge requirements for
organizational staff members and leaders
How do you
target pertinent
340B
information/
education for
different staff
positions?
Which
proficiency
assessments
would you
recommend for
different
job/positions?
17
Which Proficiency Assessments Would You
Recommend for Different Job/Positions?
18
Which Proficiency Assessments Would You
Recommend for Different Job/Positions?
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Action Items: Staff Knowledge Requirements
Action items for Staff
Knowledge
Requirements
are located on page 14
of the Compliance
Improvement Guide
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Action Items: 340B Knowledge Self-Assessment
•
•
•
•
•
E1. Identify all individuals that belong to the following groups:
Organizational leaders that need to understand how the 340B
program impacts organizational mission, financial goals,
legal/regulatory requirements, and risk management
Operational management staff that have responsibility for
establishing and maintaining processes related to 340B drug
procurement, inventory management, patient eligibility, and
billing
Departmental leaders that have responsibility for provider and
staff recruitment and performance
Staff (including students, temporary, and as-needed personnel)
that must carry out policies and procedures at the frontline and
patient engagement level
Providers and organizations at access points served by eligible
patients
E2. Determine which education
knowledge assessment areas
relate to each group
E4. Establish expectations that
340B education and
competency is an ongoing
process requiring regular
updating and verification
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Strategic Aim: Education and Training
Improvement
Concept:
Interview
Questions:
Identify gaps in staff knowledge and skills related to the
340B Program
How do you assess if your
staff has the minimum
knowledge requirements set
by your organization?
How would you use the
compliance assessments
to identify people in your
organization who need
additional 340B
education?
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How Do You Assess if Your Staff Has the Minimum
Knowledge Requirements Set by Your Organization?
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Strategic Aim: Education and Training
Improvement
Concept:
Interview
Questions:
Identify gaps in staff knowledge and skills related to the
340B Program
How do you assess if your
staff has the minimum
knowledge requirements set
by your organization?
How would you use the
compliance assessments
to identify people in your
organization who need
additional 340B
education?
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Compliance Assessment vs. Proficiency Assessment
Compliance Assessments:
• Appendix A & Appendix B in the
Guide (pg. 26-28)
Proficiency Assessments:
• Appendix C-J in the Guide (pg. 29-39)
25
Action Items: 340B Knowledge Self-Assessment
Action items for 340B
Knowledge SelfAssessment
are located on page 14
of the Compliance
Improvement Guide
26
Action Items: 340B Knowledge Self-Assessment
F1. Have every
person identified in
improvement
Concept E complete
the 340B knowledge
self –assessment
areas that are
relevant to his or her
group
F2. Compile results of
all 340B knowledge
self-assessments to
identify aggregate
knowledge gaps of
each group and
individual staff
members
F3. Utilize audit
findings to isolate and
close specific
departmental, job
category, and staff
knowledge gaps
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Strategic Aim: Education and Training
Improvement
Concept:
Interview
Questions:
Establish mechanisms and expectations for staff to develop
and maintain 340B knowledge and skills
Action Item:
“Develop and
implement an
organization-wide
education and
training strategy.”
Is this something
that you have
done? How?
If an organization
was beginning this
process and wanted
to start an
organization-wide
education strategy,
what do you
recommend should
be their first step?
How do you
use your
policies and
procedures
to ensure
appropriate
340B
education?
28
Action Items: Continuous Learning
Action items for
Continuous Learning
are located on page 14
of the Compliance
Improvement Guide
29
Action Items: Continuous Learning
G1. Develop and
implement an
organization-wide
education and training
strategy to address
knowledge gaps identified
in the self-assessment
G2. Establish a convenient
mechanism for staff to
access and complete the
necessary 340B education
and training resources
G3. Create a system to
monitor and verify that
staff acquire and maintain
the 340B knowledge and
skills as specified in their
position description
G4. Integrate 340B
education and training in
new staff orientation
processes, performance
evaluations, and
employee accountability
requirements
G6. Identify and
recommend that staff
view and complete
pertinent education
offerings available
through the 340B Prime
Vendor Program managed
by Apexus and the 340B
University
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Group Activity
Webinar Polling Question:
Which of the following will you do next week to improve your organization’s 340B
education and training program?
Select All That Apply
• Review proficiency self assessments
• Evaluate organization’s policies and procedures to include additional
educational opportunities
• Work to establish minimum 340B requirements for each job description
• Other (Please provide additional items in the second poll box)
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CPE Self Assessment Question
Webinar Polling Question:
Which of the following is incorrect:
Select One
1) Minimum 340B knowledge requirements should be tailored to different departmental or staff
member needs based on 340B roles and responsibilities.
2) Customized or targeted 340B training and education is likely to increase total individual training
time and increase knowledge retention.
3) Staff 340B knowledge gaps can be assessed using the topic areas defined in the 340B Compliance
Guide Proficiency Self Assessments.
4) One mechanism to attain initial 340B knowledge and skills is to incorporate a
mandatory training session during new employee orientation.
5) Covered entities should define their 340B training and education expectations and requirements
within organization policies and procedures.
32
How to Claim CPE Credit
A82W
To obtain CPE credit for this activity, go to:
•
•
•
•
•
http://www.pharmacist.com/live-activities
Login
Click “claim credit” or “add to cart”
“Enroll” in the activity
Complete the assessment and evaluation
Your CPE must be filed by Friday 2/12/16 at
11:59 Eastern Time in order to receive credit.
33
Open Office
Still have questions?
Join the webinar speakers on January 27, 2016 at 2pm ET
Questions for the Open Office session will be from:
Open Office registration
Overflow of questions from this webinar
Webinar satisfaction survey
Questions during Q/A
Participants must submit question(s) by January 15, 2016
Register Today to join this interactive discussion!
34
Additional Events & Resources
Training
Webinars
• Prior Webinars – Listed on the OPA Website
• Upcoming – February 10, 2016 2pm ET
340B Compliance Improvement Webinar
Series: Integrated 340B Systems
340B University™
•
•
•
•
•
January 25/26 – Grapevine, TX
February 16/17 – San Diego, CA
Register
340B University OnDemand™
More Information ApexusAnwers@340BPVP.com
Communications
Monthly Update
• Important Peer-to-Peer communications the
1st week of the month
• Sign up today!
LinkedIn
• Join the discussion on the group page
340B Resource Network
35
Compliance Improvement Model Links
Introductory Video
Compliance Improvement
Guide
• https://www.brainshark.com/aphanet/340BCompliance
• http://p2pcomplianceguide.com/latest.aspx
340B Compliance Rapid SelfAssessment – Appendix A
• http://complianceassessmentA.com/form.aspx
340B Compliance Culture SelfAssessment – Appendix B
• http://complianceassessmentB.com/form.aspx
340B Proficiency
Self-Assessments C-J
Register Now!
• Pages 29-39 of Guide
• http://p2pcomplianceguide.com/latest.aspx
• http://www.hrsa.gov/opa/peertopeer/webinars.html
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Contact Information
340B Program
340B Peer-to-Peer
Program
Apexus Answers
340B Technical
Assistance
• www.hrsa.gov/opa
• http://www.hrsa.gov/opa/peerto
peer/index.html
• 1-888-340-2787
• ApexusAnswers@340Bpvp.com
• https://www.340bpvp.com
37
www.340bPVP.com
340B University™
& 340B
OnDemand
www.340Bpvp.com/340BUniversity
ASSISTANCE
340B Prime
Vendor Program
EDUCATION
CONTRACTING
Solutions for 340B Entities
Apexus Answers
Call Center
(888) 340-BPVP
ApexusAnswers@340bP
VP.com
38