While at ValueOptions as CEO over the NorthSTAR region, Jack integrated management programs into newly formed accountable care organizations and behavioral health homes. He built consensus in the region and introduced a recovery-oriented approach. Jack helped build a sturdy, yet flexible, public health system that can withstand the strongest of challenges.

“Managed care and maintaining a proactive relationship with government has become significant as we offer better access to quality care to improve the well-being of those we serve,” says Chris Hotchkiss, CaptureRx^® President. “For the at-risk and under-served populations assisted by the 340B program, having Jack with CaptureRx^® ultimately means better patient care and outcomes.”

In addition to technology and operations activities, CaptureRx^® provides clients with support for 340B-related government policy and industry relations. Its Government and Industry Division is led by former U.S. Rep. Billy Tauzin; Tauzin was Chairman of the House Energy and Commerce Committee, and former President of the Pharmaceutical Research and Manufacturers Association (PhRMA). Jack Szczepanowski will enhance this effort, amplifying client care and maximizing CaptureRx^®’ relationships.

“CaptureRx^® is Expanding Healthcare^TM every day — it is the company’s mission, and it resonates with me” adds Szczepanowki.

CaptureRx^® has a national presence with millions of patient transactions by uniting qualified entities such as hospitals and clinics with chain, independent, and independent pharmacy group (IPGs) pharmacies as it administrates the 340B drug program.

CaptureRx^®, formed in 1999 in San Antonio, Texas, is one of the largest 340B administrators in the United States serving safety-net clinics, hospitals and pharmacies. CaptureRx^® services have positively impacted millions of patients, uniting patients and pharmacies while lowering drug costs through innovative pharmacy benefit management, and the use of contracted pharmacy network-based delivery of Public Health Service 340B, Group Purchasing Organizations (GPO), Own Use and Pharmaceutical Assistance Program (PAP) drugs.

Today, CaptureRx^® is a pioneer and technology leader in 340B processing, and automation, through Cumulus™, its proprietary system leveraging web-based technology. For information on how your program can use participating pharmacies and entities in the CaptureRx^® partnership, please email Care@CaptureRx.com or call the CaptureRx^® 340B, GPO Medical and PBM professionals toll-free at 1-888-345-6424.

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.

CUMULUS^TM, the proprietary system leveraging web-based technology by CaptureRx^®, announces migrating all clients to Version 3.0.

“CUMULUS^TM V3.0 wraps all the great features of 2.5, and offers easier use, operability and dynamic reporting,” confirms Nichol Rodriguez, Client Services Team Leader at CaptureRx^®. Client Service teams are ready to assist 340B, GPO, and PBM partners requiring support and training, if needed, for the migration. Clients will use the same login for a seamless transition.

In early May 2012, Version 3.0 will become the only available login for CaptureRx^® hospital, clinic, FQHC and pharmacy partners. CUMULUS^TM V3.0 login is nimble, the dashboard is clean and informative, and the system is more responsive.

While partner clients on the entity and pharmacy sides will enjoy V3.0, the technology team at CaptureRx^® has been developing the next generation of CUMULUS^TM. More about the next generation of robust processing and tracking for 340B, GPO, and PBM partners will come in the future.

Rodriguez adds, “CUMULUS^TM V3.0 integrates a revolutionary and readily available browser-based plugin that makes the front-end better, easier, and faster. Combined with the technological advancements, client partners will enjoy the superior interface and usability.”

CaptureRx^®, formed in 1999 in San Antonio, Texas, is one of the largest 340B administrators in the United States serving safety-net clinics, hospitals and pharmacies. CaptureRx^® services have positively impacted millions of patients, uniting patients and pharmacies while lowering drug costs through innovative pharmacy benefit management, and the use of contracted pharmacy network-based delivery of Public Health Service 340B, Group Purchasing Organizations (GPO), Own Use and Pharmaceutical Assistance Program (PAP) drugs.

Today, CaptureRx^® is a pioneer and technology leader in 340B processing, and automation, through Cumulus™, its proprietary system leveraging web-based technology. For information on how your program can use participating 340b pharmacies and entities in the CaptureRx^® partnership, please contact care@CaptureRx.com or call the CaptureRx^® 340B, GPO and PBM professionals toll-free at 1-888-345-6424.

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.

“We are delighted to have Alisa Cash take technology processes and implementation to new heights as we work together to offer better access to quality care to improve the well-being of those we serve,” says Dean Brown, CaptureRx® Chief Operating Officer. “National clients such as Rite Aid Pharmacy, Kroger Pharmacy, and others coupled with leading hospital systems and clinics put much needed pharmaceuticals in the hands of the underserved and populations in need. CaptureRx® fully supports the mission of its clients through its expert 340B plan administration.”

Alisa Cash comprises the best of senior management and information technology leadership, with successes in delivery methods spanning the full systems implementation lifecycle and ongoing operations, and leveraging global delivery models. Cash is a results-oriented leader who consistently delivers, demonstrates strong skills in multifunction areas, and is highly effective. She joins CaptureRx® having developed her professional acumen through tenure at Clear Channel Communications, H-E-B, and Accenture where she worked with notable Fortune companies in the healthcare sector.

“I stand by the vision of CaptureRx® in Expanding Healthcare^TM and look forward to best serving our existing and future clients as our team enhances their offerings and mission” adds Cash.

In addition to technology and operations activities, CaptureRx® provides clients with support for 340B-related government policy and industry relations. Its Government and Industry Division is led by former U.S. Rep. Billy Tauzin; Tauzin was Chairman of the House Energy and Commerce Committee, and former President of the Pharmaceutical Research and Manufacturers Association (PhRMA).

CaptureRx^®, formed in 1999 in San Antonio, Texas, is one of the largest 340B administrators in the nation serving safety-net clinics, hospitals and pharmacies. CaptureRx^® services have positively impacted millions of patients, uniting patients and pharmacies while lowering drug costs through innovative pharmacy benefit management, and the use of contracted pharmacy network-based delivery of Public Health Service 340B, Group Purchasing Organizations (GPO), Own Use and Pharmaceutical Assistance Program (PAP) drugs.

Today, CaptureRx® manages one of the largest 340 b programs, operates the nation’s largest 340B contracted pharmacy network, and is a pioneer and technology leader in 340B processing, and automation, through Cumulus™, its proprietary system leveraging web-based technology. For information on how your program can use participating pharmacies and entities in the CaptureRx^® network, please click www.CaptureRx.com or call the CaptureRx^® 340B professionals toll-free at 1-888-345-6424.

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.

Concept: The need for the creation of a plan of correction by State Medicaid on 340B drug identification for Medicaid managed care prescription claims.

Presented by: the Honorable Billy Tauzin, former U.S. Congressman, Chairman of the Energy and Commerce Committee and past President of the Pharmaceutical Research and Manufacturers Association (PhRMA); and J. Edward Gilmartin, COO and Co-founder of CaptureRx®, one of the nation’s largest 340B Drug Program Administrators for safety-net clinics and hospitals.

Background

States Benefit from New Large Rebate Revenue Stream
Prior to the Federal Patient Protect and Affordable Care Act (PPACA), drugs furnished by Medicaid managed care plans were exempt from rebates that the States receive for Medicaid fee-for-service under the Omnibus Reconciliation Act of 1990 (OBRA90). PPACA extended Medicaid fee-for-service drug rebates to Medicaid managed care which now allows States to enjoy a new large revenue stream. At the same time, however, 340B drugs were specifically exempted from this requirement and the new revenue stream for states.1

Benefits of 340B to Safety-net Clinics and Hospitals
Congress created the 340B program in 1992 to enable safety-net clinics and hospitals to stretch their scarce resources so that they may “reach more patients” and furnish “more comprehensive services.”2 The 340B program allows these providers the ability to purchase drugs for their outpatients at half the cost of the commercial market. As discussed in a recent report by the Government Accountability Office (GAO), 340B providers are using the additional revenue they receive to further the program’s purpose, such as by maintaining services, purchasing equipment, and lowering medication costs to the most vulnerable patients in our communities.3

340B Drugs Are Exempt
The purpose of the PPACA to exempt 340B drugs from the OBRA90 rebates was to protect 340B covered entities and the vulnerable patients they serve; Congress preserved the existing status quo. Prior to PPACA, States were not receiving revenue from 340B managed care drugs; and the exemption ensured that they would not receive any such revenue as a result of PPACA. This exemption also served to avoid duplicate discounts paid by drug manufactures. To avoid duplicate discounting, in which drug manufacturers would not pay rebates on already discounted 340B drugs, there must be a mechanism by which the States remove 340B claims from the Medicaid managed care claims before submitting for rebates under OBRA90.

The Issue

PPACA placed the responsibility on the States to report OBRA90 rebates for Medicaid managed care claims to drug manufacturers.4 More importantly, PPACA excludes 340B drugs from the OBRA90 submission on Medicaid managed care claims. As a result, the responsibility lies with the States to assure that 340B drugs used for Medicaid managed care claims are identified and removed from the OBRA90 rebate requests. Although clinics and hospitals can identify Medicaid managed care claims that were filled using 340B drugs, to date, there is no practical mechanism offered by States to allow for the identification, collection, and subsequent removal of 340B claims from Medicaid managed care claims submitted for the OBRA90 Rebates.

340B Identification Methods
There are two potential methods that can be used for identifying 340B claims by the pharmacy, which consists of: 1) a prospective point-of-sale (POS) method and 2) a retrospective method. The use of the prospective method must include the ability for the pharmacy to identify 340B claims at the time the prescription is being filled. However, this method can only be used when: 1) physical 340B drug inventory is on-hand at the pharmacy, and 2) when the pharmacy knows that the patient is eligible for 340B. These same requirements are obstacles for most pharmacies filling 340B prescriptions. While some pharmacies maintain physical 340B inventories in advance and know the 340B eligibility status of patients at POS, most 340B pharmacies, especially contracted pharmacies, do not. Therefore, 340B identification at POS is a non-starter. This issue is also addressed and substantiated by the pharmacy industry standards organization, the National Council of Prescription Drug Programs (NCPDP) 340B Task Force and W9 Workgroup.5

Today, most 340B dispensing pharmacies operate successfully using a retrospective identification process and a virtual inventory that replenishes the pharmacy’s on-hand retail inventory that was used to fill a 340B patient’s prescription. 340B claims are accumulated “virtually” until there are enough claims and pills of the dispensed drug to complete a full bottle size. This accumulation process can replenish the next day, or it can take up to 90 days, before a monetary credit on any balances remaining that could not complete a bottle size are remanded back to the pharmacy and the remainder of the claims are identified as retail rather than 340B.

The retrospective method of identifying 340B claims for Medicaid managed care is the only proven and workable solution. As mentioned, most 340B dispensing pharmacies do not know whether the patient is eligible when the prescription is filled. It is only when claims from pharmacies are analyzed after the prescription is dispensed to the patients. Much of this post-analysis consists of matching claims with patient eligibility files, eligible prescribers and incorporating other business edits and filters to assure compliance with the law. Many 340B eligible clinics and hospitals use administrators, like CaptureRx®, to contract 340B pharmacies, compliantly identify eligible 340B claims, manage inventories, place 340B orders for replenishment, and provide funds settlement services.

Solution

The State’s solution is to either require Medicaid managed care companies to accept 340B eligible claims identification retrospectively from 340B Covered Entities, or for the State to accept a similar file of claims directly so that the State can remove such claims from rebate invoices to drug manufacturers. Although the NCPDP 340B W9 Workgroup has proposed the use of what is called “N” reporting, by which pharmacies can retrospectively resubmit previous claims on-line and include a code that would identify 340B drug use for that claim, this is still a year out. Additionally, the Medicaid managed care companies would have to program for its acceptance, and pharmacies and their systems would need to accommodate for batching and resubmitting thousands of N transactions. Therefore the most efficient, expedient and practical solution is for the State to accept a 340B claim file directly from Covered Entities or their pharmacy or 340B administrator partners. The State could create a file repository or “Clearinghouse” to exchange files with the Covered Entities and the State.

Path Forward

The State must take swift action to allow for the retrospective identification of 340B claims from Medicaid managed care claims submitted for Federal OBRA90 rebates. This action will 1) assure compliance with federal law under PPACA; 2) mitigates duplicate discounts by drug manufacturers; and 3) will maintain the greatly needed revenue stream for safety-net providers in the State. Furthermore, there must be a process by which any Medicaid managed care claims previously submitted for rebate by the State, in which 340B drugs were consequently dispensed, must be re-invoiced through credits back to drug manufacturers.

CaptureRx®, the 340B Covered Entities and pharmacy providers it represents, requests by Executive Order by the Office of the Governor, that the Medicaid State Agency be tasked with a plan of correction mandating retrospective 340B claim processing for compliance, accuracy, and widespread adoption. As a technology and national-presence industry frontrunner, CaptureRx® leadership is available to assist with methodologies, technologies, piloting a project, and to formalize a plan that could be executed for the State.

References

1 42 USC §1396r-8[j][1][Covered outpatient drugs are not subject to the requirements of this section if such drugs are [A] dispensed by … Medicaid managed care organizations…; and [B] subject to discounts under section 340B…].
2 H.R. Rep. 102-384, pt.2, at 12 [1992].
3 Drug Pricing Manufacturer Discounts in the 340B Program Offer Benefits, but Federal Oversight Needs Improvement, GAO-1-836 [Sept. 2011].
4 42 USC §1396r-8[b][2][Each State … shall report to each manufacturer…information on … each covered outpatient drug… for which payment was made…, including such information reported by each managed care organization…]
5 Nat’l Council of Prescription Drug Programs, 340B Information Exchange Reference Guide [July 2011].

For more information:

J. Edward C. Gilmartin, Senior Vice President | COO
10100 Reunion Place, Suite 700, San Antonio, Texas 78216
o 210-587-1311 / c 210-325-8988 / f 210-576-0420

© COPYRIGHT 2012. CAPTURERX®. ALL RIGHTS RESERVED.

CaptureRx® welcomes Rite Aid Pharmacies to its extensive 340B national pharmacy network comprising more than 16,000 chain, independent, and independent pharmacy group (IPGs) pharmacies. Rite Aid brings more than 4,700 stores nationwide to the 340B clinics and health centers served by CaptureRx®.

As the 340B technology vendor and administrator of record for Rite Aid Corporation, CaptureRx® is pleased to serve Rite Aid’s, in addition to all of its client pharmacies’, patrons. Through CaptureRx®, Rite Aid will offer contract pharmacy services to dispense 340B-priced drugs to patients of eligible community health centers and hospitals nationwide.

“We are delighted to welcome Rite Aid to our extensive network as we work together to offer better access to quality care to improve the well-being of the communities we serve,” added Edward Gilmartin, CaptureRx® Chief Operating Officer. “CaptureRx® expands healthcare, and Rite Aid is an important part of that delivery.”

In addition to technology and operations activities, CaptureRx® will provides Rite Aid and other clients with support for 340B-related government policy and industry relations. Its Government and Industry Division is led by former U.S. Rep. Billy Tauzin; Tauzin was Chairman of the House Energy and Commerce Committee, and former President of the Pharmaceutical Research and Manufacturers Association (PhRMA).

Currently, Rite Aid is engaging pilot programs throughout the country with CaptureRx® and plans to offer 340B services nationally. If you would like further information, visit Rite Aid’s 340B site at www.RiteAid340B.com.

For information on how your program can use Rite Aid and other participating pharmacies in the CaptureRx® network, please click www.CaptureRx.com or call CaptureRx® 340B professionals toll-free at 1-888-345-6424.

CaptureRx®, formed in 1999 in San Antonio, Texas, is one of the largest 340B administrators in the nation serving safety-net clinics, hospitals and pharmacies. CaptureRx® services have positively impacted millions of patients, uniting patients and pharmacies while lowering drug costs through innovative pharmacy benefit management, and the use of contracted pharmacy network-based delivery of Public Health Service 340B, Group Purchasing Organizations, Own Use and Pharmaceutical Assistance Program drugs.

Today, CaptureRx® manages one of the largest 340B programs, operates the nation’s largest 340B contracted pharmacy network, and is a pioneer and technology leader in 340B processing, and automation, through Cumulus™, its proprietary internet “cloud” based platform. For more information, visit www.capturerx.com.

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.

What: 340B Coalition Winter Conference

Where: The Hotel Del Coronado, San Diego, CA   Booth 23

When: February 29 – March 2

CaptureRx^® built Cumulus^™ to excel with virtually compliant core functionality – without peer. Engineered for compliance, audit and accountable, robust performance across any size network, Cumulus^™  is designed to be the preeminent 340B processing and automation solution.

Experience Cumulus^™ personally in San Diego February 29 – March 2, or anytime online from a CaptureRx^® solutions professional. Our team is here to help you with the 340B program, and what it means for the patient and your enterprise.

Find out more: care@capturerx.com.

The industry is buzzing about audit and compliance; CaptureRx^® confidently offers its capabilities. From national chain pharmacy clients to independent qualifying clinics, Cumulus^™ serves populations better, improves organizations’ bottom lines, and enhances reporting.

CaptureRx^® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers.

CaptureRx^®, formed in 1999, has been serving community health centers, safety-net clinics and hospitals for more than a decade. Millions of patients have been touched nationwide by CaptureRx^® services to unite patients and community pharmacies, and lowering drug costs through innovative pharmacy benefit management through the use of contracted pharmacy network-based delivery of Public Health Service 340B, GPO and Own Use, and PAP drugs.

CaptureRx^® manages one of the largest 340B programs in the country; operates the nation’s largest 340B contracted pharmacy network, and is a pioneer and technology leader in 340B processing and automation through its proprietary internet “cloud” based platform Cumulus^™.

CaptureRx^® is currently engaged with hundreds of community health centers, hospitals, & managed care programs nationwide.

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.

FQHCs Are Eligible to Become ACOs

This is a great opportunity for Accountable Care Organizations (ACOs) to take advantage of and partner with Covered Entities that are eligible for 340B drug pricing. Although there is a great deal of talk about ACOs, there is still much to be done to put all the pieces together; integrating systems, establishing data warehouses, and creating business intelligence rules to aid in data mining. With that said, some clarifications and changes came in the last week when the final rule was published which differs in seven areas from the proposed rule. The best news was that there were additional groups recognized to both be eligible to form and to participate in an ACO, which are federally qualified health care centers and rural health clinics.

One of the most surprising was that no longer is the electronic health record a condition for participation. Previously 50% of primary care physicians were to be defined as meaningful users by the start of the second performance year. Although this changed, the E.H.R. was retained as a quality measure and is rated higher than other measures for quality scoring purposes. There were also modifications to contacting beneficiaries from quarterly lists to notify them of data sharing and an opportunity to decline which previously only allowed data sharing of claims data for patients seen by ACO primary care physician during the performance year with beneficiaries given the opportunity to decline at POC.

Other areas which changed in the final rule were the start date which allows much more flexibility, aggregate reports-additional reports will be provided unsure what these are yet, assignment process changing from a one step to a two step process and marketing guidelines new file and use which is a less cumbersome process. To learn more about pharmacy benefits management, follow our blog at CaptureRx.

Holly E. Russo, RN, MSN, MS, ECS
Vice President Hospitals and Health Systems, Chief Clinical Officer
holly.russo@capturerx.com

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.

Humana and Pfizer announced today a research collaboration focused on improving care for seniors suffering from chronic conditions in primary care settings. The aim is to better understand the needs of those persons 65 years of age and above and develop effective treatments and care to meet their needs effectively and efficiently through collaboration.

These type of collaborations are increasing as we look to ways to employ population health strategies. This targeted group is a subpopulation which continues to increase with the U.S. Census estimating that by 2020 the Medicare-eligible population will reach 65 million – a 36% increase in ten years which consumes a great deal of health care resources making it imperative to look at cost effective approaches to managing chronic disease.

While healthcare policy has been a hot topic of late, one component is consistently overlooked: payment policy.

Because this is a vital component to reform, I wanted to get some thoughts on the subject from an industry expert. I had the privilege to listen to Jack Wennberg, one of the fathers of assessing variation and its impact on costs and quality.

“If healthcare reform reform concentrates on four goals,” Wennberg said, “then the value of care will increase and growth in healthcare costs will decrease.” The goals are as follows: 1) promote organized healthcare delivery; 2) establish informed patient choice around tests, procedures, drugs, elective surgeries and end-of-life care; 3) improve the science of healthcare delivery; and 4) constrain undisciplined growth in spending and capacity.

To accomplish these goals we must understand the questions to ask, the data needed to make assessments, the significance of conclusions reached and the strategies needed to make successful change.

There are some potential hiccups. For example, drug therapy may have potential conflicts among patient preference, administration goals, and clinicians around prescriptions.

For years, hospitals have encouraged generic medications inside hospital walls. However, in outpatient-filled prescriptions, brands produce more revenue. Many patients prefer brand-name medicine, but many experts question patient understanding of generic equivalents.

This issue is an example of a topic where many people may avoid the problem rather than candidly tackle it to understand how to make informed and ethical decisions.

Today we face some of the most significant changes in payment policy, and an increased focus on quality of care to outcome and reimbursement. Those who try to hide from the problems will be out of business; however, those that look critically at how, where and when care is accessed and delivered will be ready to embrace the future.

It is important that we approach the issues directly and transparently share our results so we can better deliver care. For more information on GPO medical and 340b programs.

Holly E. Russo, RN, MSN, MS, ECS
Vice President Hospitals and Health Systems, Chief Clinical Officer
holly.russo@capturerx.com

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.

Last month, the Government Accountability Office issued a critical report on the 340B program. GAO interviewed 61 stakeholders in the program about their ability to generate revenue and distribute drugs. GAO also examined the adequacy of federal oversight of the program.

The main thrust of the report is that 340B needs better federal oversight, identifies areas of the program that need clarification and warrant discussion. But the government should not act upon the findings because the review was flawed and undermined by sampling bias and size.

My first takeaway from the report is that existing technological solutions would simultaneously provide transparency within the 340B program and ensure adherence to it. These technologies can help entities make informed decisions while reassuring the government that the industry is meeting standards.

The report raises questions about how two organizations utilize the program. Unfortunately, GAO never specifically cites an example of 340B being abused; it just insinuates problems in a prescriber area that causes much confusion, with some entities interpreting it too narrowly and others too broadly. The government could alleviate this concern by clarifying its intent.

GAO also raises concerns about access of covered entities for certain drugs caused by drug shortages, but the agency offers no real strategies to address this issue.

Despite a small sample size and a bias in interviewee selections, the report makes some valid observations. Many covered entities are using revenue gained through the 340B program to either provide access to services, increase services available, subsidize care for the uninsured or just simply keep their doors open.

However, only 13 of the 20 entities interviewed — or roughly 60 percent — are generating revenue. That does not fairly represent participants in the program.

GAO falls short of actually saying there is a real problem with diversion, duplication, discounting and overcharging by manufacturers. Rather, it makes rash generalizations without sufficient data to support the claims.

Programs like 340B are not perfect, but they provide an important service to our under-insured and uninsured citizens. I hope that future GAO studies will include larger sample sizes and will not operate under the impression that the program is inherently flawed.

CaptureRX® delivers pharmacy benefits management, 340B, and GPO solutions to America’s hospitals and health centers. For more information, please visit http://capturerx.com.