March 2015 HRSA’s efforts to improve 340B program integrity are not limited to audits; ensuring the accuracy of initial registrations is a critical priority as well. HRSA has been working to integrate authoritative external data sources with the registration process for the last several years, beginning with the validation of contract pharmacy information via Drug Enforcement Agency databases in March 2013 as well as the simultaneous automatic verification of Consolidated Health Center Program (Section 330) grantees and Federally Qualified Health Center Look-Alike (FQHCLA) organizations using HRSA’s Electronic Handbooks system. These enhancements have yielded improved data quality as well as efficiencies for both registrants and HRSA staff. In July 2014, HRSA began a new process whereby cost report and provider registration data from the Centers for Medicare & Medicaid Services (CMS) are used to improve the efficiency and integrity of the 340B hospital registration process. Upon registration, the dates of the cost reporting period from the most recently filed report available from CMS are displayed to the hospital, as well as the associated control type (ownership status) and Disproportionate Share adjustment percentage as applicable. Hospitals registering additional off-site outpatient facilities are prompted to select from a list of practice locations registered with CMS via the CMS-855A/B forms or the Provider Enrollment, Chain and Ownership System (PECOS). HRSA would like to encourage the following best practices based upon lessons learned during the new hospital registration process:
HRSA appreciates the cooperation of the 340B community as we continue to refine the hospital and non-hospital registration processes in support of an effective, efficient and transparent program. We anticipate the integration of additional external grantee data sources in late 2015 or early 2016. As always, the team at ApexusAnswers – a service of the 340B contracted Prime Vendor Program – stands ready to assist with any questions or concerns by e-mail (ApexusAnswers@340bpvp.com), phone (888-340-2787) or online chat. |
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