Co-hosts Chelsea Violette and Logan Yoho dive into the strategy behind building in-house pharmacies in “340B & Entity-Owned Pharmacies: What to Know Before You Start.” Joined by guest Michael Gonzalez, Founder of FQHC 340B Compliance, this episode unpacks the why, how, and what's next for entity-owned pharmacies in the 340B space.
Michael Gonzalez is a healthcare consultant with eight years of experience in 340B Program and pharmacy management services, offering comprehensive support including program coordination, audits, and pharmacy development. Previously, he served as audit manager at Terry Horne C.P.A. & Associates, where he conducted over 120 audits and provided expertise in FQHC financial advisory services during his four-year tenure.
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Welcome to the 340 Banter Podcast. In today's episode, we'll be discussing entity-owned pharmacies.
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Recently, many covered entities have wanted to investigate opening an entity-owned
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pharmacy, but don't know where to start.
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We'll discuss what you should think about before you open a pharmacy,
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as well as tips to help it succeed once it is opened.
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You know, with all the manufacturer restrictions we've been seeing around contract
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pharmacies, we've really seen covered entities take a significant hit to their 340B savings.
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And it's really impacted patient care with layoffs and different service lines
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needing to be trimmed down.
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And one of the things that we're seeing a lot is covered entities look to entity-owned
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or in-house pharmacies, either starting a new one,
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adding to an existing one, or optimizing ones that they already have to try
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to make the most of the 340B savings within there.
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Logan, working within our pharmacy services service line, I was wondering if
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you could kind of talk to us about what you're seeing as you're walking health
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centers through adding their own in-house pharmacy.
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Yeah, I really think it's become a very popular service line.
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We're having more and more people come to us asking us if it's possible.
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And I think that that's the first step.
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Is an entity-owned pharmacy ripe for every covered entity?
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Probably not. But unfortunately, I know it's really hurting some of the smaller
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FQHCs, but you have to have that volume of prescriptions to really make it valuable.
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But we're talking to health centers all over the country that are really seeking
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to see if it's right for them.
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What are things, aside from having a smaller organization with just smaller
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script volume in general, what are other things that might contribute to an
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entity-owned pharmacy maybe not being the right thing?
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Pick for a certain organization. I think the other thing is paramix.
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So we commonly, when we're looking at that, we're pulling for health centers,
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we're pulling UDS data because we can pull that paramix right off of HRSA's website.
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Hospitals would have the same stuff in their cost reports as well. Exactly.
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So it's important to know that for a couple reasons.
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One, you're going to want to know how many unassured patients you're going to
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have because really we're not
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making money on our uninsured patients were there to provide a service.
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And the goal is to break even, maybe pay for the time of the pharmacist to dispense that prescription.
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But even some health centers don't do that. They subsidize that cost for their uninsured patients.
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But that makes a burden on the health center financially.
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The other thing is really knowing the Medicaid rules in your specific state.
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Some states, like mine of Ohio, we preserve our 340B savings on our managed care Medicaid claims.
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So it allows us to be reimbursed at a level where we still maintain those savings.
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Where what we're seeing in a lot of states is that even managed care Medicaid
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is being reimbursed at a fee-for-service logic.
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And that's the acquisition cost of the drug plus a professional dispensing fee.
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And while that's pretty much a break-even, which isn't bad, but it makes it
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hard if you have a very high Medicaid percentage to keep the pharmacy sustainable.
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Doesn't give you a lot of buffer room. Also, I feel like, you know, not all states',
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professional dispensing fee is equivalent to the overhead, you know,
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the admin fee that you typically would assign to a prescription at just as part
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of your usual and customary billing in the pharmacy.
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The cost of billing a bottle of air is typically higher.
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Another thing, too, is that even if you're a small health center,
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it doesn't mean that the pharmacy is not right for you, right?
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Now, is it more likely that it may not be for you?
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Yes, but based on your, you know, we kind of talked based on your payers from
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a perspective of it not being financially viable.
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Also, based on your payers, we can find that it is financially viable at a small
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health center. In addition to the payers, it's also what specialties you have.
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Because some specialties come with just drugs that typically have a higher 340B savings.
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So if you have just primary care, it may be a little challenging if they're
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pretty much dispensing generic medication.
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But if you're doing HIV care, you may be able to sustain a program,
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a pharmacy program, with less prescription volume. them.
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The thing I think that's really cool there is that that becomes kind of mutually sustainable.
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So your specialties where the medications associated with them might have a larger 340B savings.
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That then helps the organization reinvest in treating that condition or that
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disease state or adding in services for another one.
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So we've seen a lot of organizations through their 340B programs and through
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the savings generated just from their entity-owned pharmacy be able to add things
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like hepatitis C treatment or HIV treatment or more mental health,
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excuse me, more mental health services or homeless, you know,
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homeless shelter or health care.
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And so I think that, you know, those drive the prescriptions that might help
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the organization increase 340B savings.
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And then that 340B savings is often directly invested right back into expanding
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access to care that's really hard to get, particularly in some rural areas.
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We're seeing a lot of health centers also, you mentioned hepatitis C.
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We're seeing health centers be able to start clinical pharmacy interventions
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as well through that because clinical pharmacy services aren't always reimbursable.
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So that's a great way to use your 340B savings.
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And it's a symbiotic relationship. So once you start a clinical pharmacy program
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that's getting hepatitis C treatment out there, one, it's great clinically because
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you're curing a viral disease for the patient.
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You're curing it. And two, it's creating more and more 340B revenue,
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which allows you to keep funding those services.
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And even outside of specialty, I think clinical pharmacy brings a lot of value and has that, you know,
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a mutual connected relationship with the in-house pharmacy. The more my patient
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gets familiar with our pharmacy team, you know, we see a lot of health centers
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will, will kind of rotate where, you know, you have certain days you work in
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the pharmacy, certain days you work on the clinical side.
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And, you know, not that we're, you don't steer prescriptions,
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you're not trying to steer a prescription, but the, the patient is more involved with your team now.
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And so the likelihood of them, you know, if they see your pharmacist on the
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clinical side and then, you know, next week, I'm going to be able to see them
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inside the pharmacy when I pick up my medication.
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I think you have a likelihood of higher capture rate. Yeah. And just.
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Increased level of trust. Right.
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And along with the steering, I think that that's a good point.
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Or lack of. Or lack of steering.
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That discussion, I think it's a good point to discuss because that scares a lot of health centers.
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Because you're not prohibited to steer your patient's prescriptions to your
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entity-owned pharmacy.
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But I think it's important to take a step back, think about pharmacy the way
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you think about every other specialty.
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Can I, sorry, I want to revisit because I think you said you're not prohibited
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from steering your patients to your own pharmacy and you don't want to remove,
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we're not saying that you're removing the patient's choice in where to fill
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their prescription as opposed to steering.
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We're more providing education about the additional services and level of care
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they would get from your pharmacy.
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Sorry, I just wanted to. Take us off the rails here, Logan. So I think I think
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they're if you think about it as another specialty our providers are not.
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Concerned with recommending a cardiologist that works really well with them
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that they have a good relationship with.
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Does the patient have to use that cardiologist? No.
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They can go to a different cardiologist. They can say, I want to use this other
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cardiologist, but that's not considered steering.
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That's explaining a clinical benefit and a communication benefit to using that cardiologist.
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I think the same goes for pharmacy.
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Your medical providers have a lot of trust with their patients so they can communicate
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that and say, these are the clinical benefits to using our entity-owned pharmacy.
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I think that point is a great one to build on because we talked about the benefit
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from the 340B savings, reestablishing those 340B savings within an entity-owned
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pharmacy, particularly if you're feeling that loss from the contract pharmacy restrictions.
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But there are so many benefits to entity-owned pharmacies
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outside of just the 340B savings and
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the financial aspects and i think it's worth discussing some
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of those because that can help the the decision
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making process on if an entity-owned pharmacy is right
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for a certain organization yeah and
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i think that kind of you know the start of
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that is is more of a family setting almost right because like
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rather than i'm going to see this corporation and then
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i have to go get this at this corporation when it's all in one family you know
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leadership is the same they should be operate not necessarily operating but
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the way they do business should be the same you know the mindset of of what
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we stand behind you know how we're going to provide our support.
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And not that independence you know independence do a great job at supporting
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their patients and the community but it just it makes everything a little bit
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simpler so yeah and i know you know i think you're caveating more of.
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I don't know if caveating is the right word, but you're going more into the
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patient care side because there's benefits from just patient care.
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But I think just from a personal relationship side, it's better to deal with one entity.
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It just feels more homey. You know, I don't know if that makes sense.
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I mean, I'll say from the patient care side and the better connection side of things,
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by the pure nature of being in the same building as the health center in many
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cases and having access to the same medical record, it streamlines so much.
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Having worked as a retail pharmacist, both in pharmacy within my FQHC and also
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in a retail pharmacy outside of the FQHC,
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having to correct a prescription or call about dosing to clarify something or
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needing to change a prescription because we have information about an allergy
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that maybe the physician didn't have.
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Being in the health center makes that so much more seamless.
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Just from the pharmacist workflow point of view, but also from the patient's
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point of view, it's so frustrating as a patient when you're already sick,
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already having a really bad day, go to a pharmacy and they say,
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you know, there's a problem with the prescription.
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We have to talk to your provider. And then it takes them two days to get clarification and get that back.
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And you're already feeling terrible. You're already having to drive to multiple
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places, what have you, not in the medication when you need to be.
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And in the pharmacy attached to the health center, you can call the provider's MA.
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That's right down the hall. You can go check in the medical record to see what
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they discussed during the visit.
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Maybe there was a reason for choosing this specific thing, even though there's a documented allergy.
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They talked more about what the reaction was and this medication's okay now.
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Or I could just go down the hall and ask them, grab them on their way out of
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their pod, from their desk or on their way into a visit. Hey,
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can I clarify a prescription real quick?
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And we're able to help that patient before they've left the building the first
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time and actually get that taken care of.
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I would stand outside the exam room until they came out and catch them.
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Another benefit, especially to health centers, and I'm sure it applies to the
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hospital space as well, are your value-based care agreements.
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That's becoming more and more important for health centers is that you're being
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paid in a different manner instead of a fee-for-service logic.
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You're getting paid based on performance.
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And almost every one of those measures is directly or indirectly impacted by pharmacy care.
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So by getting a patient adherent on something like their statins,
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it's going to decrease their risk for heart attack or stroke.
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And by really putting a focus on that entity on pharmacy, you're going to increase
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adherence to drugs and have better patient care,
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and that will indirectly provide more revenue for the health center by improving
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those performance measures. Right.
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And then, you know, pharmacy is the retail side of pharmacy is not what it used to be.
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It's very difficult. And so if we look at it from a business model,
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because of 340 being an in-house pharmacy.
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W we essentially have more time to spend with the patient right
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our pharmacists have more time to to interact with that patient
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because independent retail pharmacy is a
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very tough game right they have to squeeze every penny out of everything they
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can get now that i'm not you know they love their communities they go above
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and beyond for their patients but at the same time they also have to make business
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sense they have to be able to pay their salaries they have to be able to pay their overhead,
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they don't get federal grants to help supplement that like the FQs do.
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But even those grants are really for the medical side.
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So the 340B allows us to spend more time inside that pharmacy and get those
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interactions with those patients and make them feel comfortable with us.
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And the contract pharmacy restrictions are hitting them too.
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So it's not just the impact to the covered entity, but it's also the impact
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to our partner pharmacies.
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So they're getting hit from another direction now.
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And I just think that that's somewhere where we're able to help those more complex patients.
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One of the things, one of my providers, it took her a while to get on board
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with entity-owned pharmacy when I was at my health center.
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But one of the things that really spoke to her was that we were helping her
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patients when there was an access issue.
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So maybe it was insurance wasn't covered or
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it needed prior authorization and she said i don't
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know how many of my patients when they walk out the door don't fill
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their prescription yeah and that they can
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help if they know but they don't know right and that was a huge benefit for
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and really sold her on the entity-owned pharmacy i think one of the other cool
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things that you can do facilitating when you have or that you can facilitate
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when you have your entity-owned pharmacy is prescription assistance programs
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and those bulk replenishment medications.
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If you send a patient out for a prescription, they go to, you know,
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a retail pharmacy out in the community, can't afford it, and they come back
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to you and say, I can't afford this medication.
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There are access navigators within the health center who can help them look
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into the prescription assistance programs.
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But again, that's an additional delay in care, and it relies on the patient
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coming back and asking for help.
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Versus if you are managing it within your own entity-owned pharmacy and you
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have the ability to contract with some of the prescription assistance bulk replenishment programs,
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once you qualify patients for those, they can come get those prescriptions for
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free from your pharmacy just like everyone else.
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They're not waiting to get things in the mail. You're not relying on the patient
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to come back to the health center and seek out additional support in getting
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affordable medication.
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So it's really nice to be able to pull that in, take away any stigma from having
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to go through a different access point, take away an additional barrier to receiving
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care by letting them get it at the pharmacy just like they would otherwise.
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The same thing with vaccines, increase a lot of access to vaccine care in general
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when the pharmacists are able to provide them.
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Particularly, I know in cold and flu season, our walk-in clinic would just get
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slammed with vaccine requests, which was great.
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You want your community vaccinated to protect, but we just, a lot of times our
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health center staff didn't have the capacity for it.
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And being able to increase that capacity within the pharmacy so they're still
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in the same building, you're not sending them away somewhere else.
00:16:50.077 --> 00:16:53.817
Being able to do that was very meaningful, I know, for us. Another opportunity
00:16:53.817 --> 00:16:55.497
could be pharmacy students.
00:16:55.777 --> 00:17:00.697
It gives you the opportunity as a pharmacist to be a preceptor for pharmacy
00:17:00.697 --> 00:17:05.217
students in their final year of school, and that brings an extra person into the health center.
00:17:05.357 --> 00:17:09.657
That person can immunize, that person can work through the different pharmacy things.
00:17:09.697 --> 00:17:13.677
It doesn't mean it's free labor because it's some work on the preceptor. It is a lot of work.
00:17:14.717 --> 00:17:21.177
But it does allow you to expand your services, and students are a great way
00:17:21.177 --> 00:17:23.117
to bring fresh eyes into your pharmacy.
00:17:23.657 --> 00:17:28.197
I think we've talked a lot about the kind of the decision points that might
00:17:28.197 --> 00:17:31.497
help you get to is an entity-owned pharmacy right for your organization?
00:17:31.737 --> 00:17:36.377
And then what additional value and benefits can you derive from having your
00:17:36.377 --> 00:17:37.437
own entity-owned pharmacy?
00:17:37.637 --> 00:17:42.617
And I'd love if we could kind of wrap the conversation up by just touching on
00:17:42.617 --> 00:17:48.377
what conversation points or what partners you need within the leadership,
00:17:48.597 --> 00:17:52.957
the organizational leadership, to move an entity-owned pharmacy forward because
00:17:52.957 --> 00:17:56.877
it is not a pharmacy-specific, you know, it's not in a silo.
00:17:57.377 --> 00:18:00.957
There's so many other parts of the health care system in the health center that,
00:18:01.670 --> 00:18:04.910
play into that. So maybe you could talk a little bit about, particularly because
00:18:04.910 --> 00:18:09.310
you come from a background outside of pharmacy, how important those conversations
00:18:09.310 --> 00:18:12.990
are in discussing the viability for an entity-owned pharmacy.
00:18:13.290 --> 00:18:18.870
Yeah, even past viability, it's like, how do you maintain it as someone who
00:18:18.870 --> 00:18:22.070
doesn't understand pharmacy and how it operates?
00:18:23.010 --> 00:18:26.610
I think one of the big things that I see is,
00:18:26.750 --> 00:18:30.250
and again, this is just because that's where my best understanding is,
00:18:30.270 --> 00:18:33.030
is the accounting side yeah so you know when we go into
00:18:33.030 --> 00:18:36.230
house pharmacies and you know there's like
00:18:36.230 --> 00:18:39.150
there's almost a disconnect and i feel
00:18:39.150 --> 00:18:42.510
like we've had conversations about this before where sometimes you go into a
00:18:42.510 --> 00:18:47.770
health center and it's almost though they're the same it's almost like they're
00:18:47.770 --> 00:18:51.290
separate entities right like the pharmacy exists over here they're in the same
00:18:51.290 --> 00:18:55.790
building you know same employer same management however like they have their
00:18:55.790 --> 00:18:57.930
own thing and then medical has their own thing.
00:18:58.310 --> 00:19:02.050
And I think that from a management perspective, you want to put things in place
00:19:02.050 --> 00:19:03.310
to kind of bridge that gap.
00:19:03.710 --> 00:19:08.710
And that could be different committees that you set up to have those interactions between departments.
00:19:09.770 --> 00:19:13.050
But like my big thing is the accounting. The accounting is kind of a mess.
00:19:13.610 --> 00:19:16.250
And, you know, I've gone into some health centers where they're like,
00:19:16.390 --> 00:19:20.350
oh, well, we make the pharmacy kind of prepare that for us.
00:19:20.430 --> 00:19:24.550
And I'm like, but that's not what they understand. And that's not what we're paying them to do.
00:19:25.030 --> 00:19:29.210
And, you know, that we're not good at. Right. And so I feel that accounting,
00:19:29.410 --> 00:19:33.250
you know, your accounting department needs to understand how to run a report.
00:19:33.670 --> 00:19:38.570
Again, do they need to know the clinical benefit of this drug versus this drug? Probably not.
00:19:39.530 --> 00:19:44.050
Understand some of the nuances of the 340B program at a high level.
00:19:44.050 --> 00:19:46.410
You need to know some things. You need to know what's allowed.
00:19:46.630 --> 00:19:49.930
You need to be able to catch that. But someone in accounting should know how
00:19:49.930 --> 00:19:54.850
to run a report out of the filling system and be able to take that and understand
00:19:54.850 --> 00:19:56.110
what the data is telling them. Right.
00:19:56.430 --> 00:20:02.510
And further than that, not just understanding what it's trying to tell me, understanding when...
00:20:03.030 --> 00:20:06.350
It's not right. Like, and that's a hard thing. You don't know because you,
00:20:06.590 --> 00:20:11.130
in accounting, we're used to trusting numbers and what numbers come out of the system come out.
00:20:11.930 --> 00:20:16.870
But for some reason, pharmacy filling softwares and accounting departments kind
00:20:16.870 --> 00:20:18.310
of butt heads quite a bit.
00:20:18.390 --> 00:20:22.330
So I think it's super important for your finance team to understand that so
00:20:22.330 --> 00:20:25.250
that you're not having problems at year end when you have your single audit
00:20:25.250 --> 00:20:28.870
come in and, you know, and, and, well, I don't know why it says that number.
00:20:29.050 --> 00:20:31.790
That's what the system told me. You need to understand that,
00:20:31.890 --> 00:20:33.430
hey, that's probably not the right number.
00:20:33.590 --> 00:20:38.050
You need to have enough understanding of your pharmacy as management to be able
00:20:38.050 --> 00:20:40.330
to get a report and say, that doesn't seem right.
00:20:40.590 --> 00:20:44.510
I think that that's really important when you are starting up an entity-owned
00:20:44.510 --> 00:20:48.350
pharmacy so that you have that understanding and you're building a solid base.
00:20:48.350 --> 00:20:52.590
But I think it's so important, even once the pharmacy is up and running and
00:20:52.590 --> 00:20:56.410
having your finance team understand, like I said, that, you know,
00:20:56.550 --> 00:21:00.750
a little bit of how the 340B program works and how the different pieces interplay.
00:21:01.010 --> 00:21:05.430
Because I know that I've definitely had to deal with the perception of the 340B
00:21:05.430 --> 00:21:08.970
program or the pharmacy program being like the goose that lays the golden eggs.
00:21:09.130 --> 00:21:13.410
And like, oh, well, this has helped because honestly, health centers typically
00:21:13.410 --> 00:21:17.970
would operate in the negative without their 340B program. Absolutely.
00:21:18.250 --> 00:21:22.270
And because of that, each year coming back and saying, OK, well, we had this.
00:21:22.390 --> 00:21:25.290
We need to add this service next year. So we're going to need your department
00:21:25.290 --> 00:21:26.870
to make this much more money.
00:21:27.010 --> 00:21:30.890
And having to then tie it back to, you know, you said accountants trust numbers.
00:21:31.090 --> 00:21:33.430
So bring it back to, OK, here's how many visits we have.
00:21:33.650 --> 00:21:36.250
Here's how many prescriptions we generate out of a visit.
00:21:36.730 --> 00:21:39.990
Here's how many prescriptions we're capturing out of our, you know, in our pharmacy.
00:21:40.410 --> 00:21:44.130
Realistically, this is about what we can capture.
00:21:44.290 --> 00:21:47.270
And this isn't it's not going to infinitely grow, you know.
00:21:47.270 --> 00:21:52.690
And being able to connect those dots and have your finance team,
00:21:53.050 --> 00:21:58.850
your budgeting team understand that moving forward as well so that you're having
00:21:58.850 --> 00:22:02.050
realistic expectations within your pharmacy is really important too.
00:22:02.050 --> 00:22:08.410
I think thinking about that whole leadership approach, one of the things when
00:22:08.410 --> 00:22:13.430
I've talked to C-suite, especially when they're new to pharmacy,
00:22:13.870 --> 00:22:18.290
either getting implementation going or they just opened a pharmacy,
00:22:18.290 --> 00:22:20.490
or maybe that they're struggling.
00:22:20.490 --> 00:22:22.870
They've had one for a while and their pharmacy is struggling.
00:22:23.230 --> 00:22:28.470
One of the things I like to tell the C-suite is the pharmacy staff are the least
00:22:28.470 --> 00:22:32.050
impactful on the capture rate. Can they be impactful? Yeah.
00:22:32.390 --> 00:22:38.390
If they're giving poor service to their patients, then it's going to negatively impact it.
00:22:38.570 --> 00:22:43.750
But really the most important piece in most health centers, at least,
00:22:43.870 --> 00:22:48.630
and I'm sure this applies to other covered entity types, is that medical provider.
00:22:49.391 --> 00:22:52.651
They've developed that rapport, that trust with the patient,
00:22:52.651 --> 00:22:55.671
and they follow their recommendations.
00:22:56.071 --> 00:23:01.791
So if they're talking about the pharmacy, then it's going to succeed.
00:23:02.191 --> 00:23:04.971
But really, it needs to be an all-staff approach.
00:23:05.811 --> 00:23:10.751
Again, it's a trickle-down thing, right? So you need C-suites buy-in.
00:23:11.051 --> 00:23:15.951
You got to have it. Because if you have C-suites buy-in, they can help you get medicals buy-in.
00:23:16.071 --> 00:23:19.051
If you don't have C-suites buy-in, you have a problem.
00:23:19.931 --> 00:23:26.431
And especially for an FQ, right, we get federal funding because we provide services
00:23:26.431 --> 00:23:30.691
that are expensive for us to provide, knowing that we may be serving patients
00:23:30.691 --> 00:23:34.131
who don't have an ability to pay the expensive cost. So we're writing that down.
00:23:34.491 --> 00:23:39.971
And so in the pharmacy is really one of the, there's a few, but one of the only
00:23:39.971 --> 00:23:47.891
areas where you can typically generate income or profit versus medical or dental or behavioral health.
00:23:47.891 --> 00:23:54.551
And so to me, it just would make, I think everyone from the C-suite should buy in, right?
00:23:54.691 --> 00:23:58.271
Because this is an area where we can, and we should show it some love and we
00:23:58.271 --> 00:24:02.991
should show some, you know, we should be observing this and have discussions
00:24:02.991 --> 00:24:08.111
around what's going on in the pharmacy and fine tuning that pharmacy to operate efficiently.
00:24:08.111 --> 00:24:12.651
Because by operating efficiently, one, you know, from a business perspective,
00:24:12.871 --> 00:24:17.271
you were able to produce income, but two, you're getting better patient care.
00:24:17.451 --> 00:24:23.491
I mean, the more efficient we can be in any workflow, we get to produce a better product, right?
00:24:23.711 --> 00:24:26.171
Yeah. So, I mean, so you're pulling in, we already talked about finance.
00:24:26.171 --> 00:24:27.611
You talked about clinical leadership.
00:24:27.971 --> 00:24:32.511
You've also got quality, you know, the quality of your patient care and meeting
00:24:32.511 --> 00:24:33.991
your value-based measures.
00:24:33.991 --> 00:24:37.051
We've got compliance and legal because
00:24:37.051 --> 00:24:40.791
of the nature of a government program i
00:24:40.791 --> 00:24:44.171
i think that it touches so many different aspects of
00:24:44.171 --> 00:24:47.091
the of the covered entity of the health system that that
00:24:47.091 --> 00:24:50.011
buying is really important and so education is really important because
00:24:50.011 --> 00:24:53.111
you don't get buy-in without people understanding so i think yeah if
00:24:53.111 --> 00:24:56.211
we were to pick kind of the one major major thing to
00:24:56.211 --> 00:24:59.271
deliver to your organization if you're
00:24:59.271 --> 00:25:03.191
thinking about an entity on farms you'd probably be educating and
00:25:03.191 --> 00:25:06.691
talking with your c-suite and understanding what what values
00:25:06.691 --> 00:25:10.031
they have that a pharmacy absolutely absolutely i
00:25:10.031 --> 00:25:15.311
i agree completely that that education component one of the things when we're
00:25:15.311 --> 00:25:18.951
talking to people who've just opened a pharmacy because they're they're trying
00:25:18.951 --> 00:25:25.151
to grow their their pharmacy business is try to get included in orientation
00:25:25.151 --> 00:25:28.611
So you talk to every provider when they come on staff.
00:25:28.771 --> 00:25:31.351
So they understand how the 340B
00:25:31.351 --> 00:25:34.411
program works. So they understand how the entity-owned pharmacy works.
00:25:34.811 --> 00:25:39.291
Because the better they know how it works, the more engaged they're going to be.
"We see a lot of health centers that will rotate their team between clinical and pharmacy so that the patient is seeing your pharmacist on the clinical side and within the pharmacy, you have a likelihood of higher capture rate."
Meet Logan Yoho, PharmD, BCACP, 340B ACE, and co-host of the 340Banter Podcast. With nearly a decade of experience in the 340B industry, Logan is dedicated to helping health centers optimize and maintain successful, compliant 340B Programs. As Director of Advocacy and Education at FQHC 340B Compliance, he focuses on implementing entity-owned pharmacies and guiding advocacy efforts for 340B. Logan’s extensive background includes leading the pharmacy and 340B programs at Hopewell Health Centers, serving as Apexus 340B University Faculty, and chairing the Ohio 340B FQHC Consortium. Logan’s leadership and expertise have earned him multiple awards, and he brings a wealth of knowledge to every episode of 340Banter.
Meet Chelsea Violette, PharmD, BCACP, 340B ACE, and your co-host for the 340Banter Podcast. With over a decade of experience in pharmacy and 340B Program management, Chelsea brings a wealth of knowledge to the table. As Chief Operating Officer at FQHC 340B Compliance, she works tirelessly to support health centers across the country, ensuring they have the tools and strategies they need to succeed. Chelsea’s hands-on experience as a 340B Consultant and Pharmacy Manager, combined with her expertise as a subject matter expert for the Apexus 340B Prime Vendor Program, makes her a trusted voice in the world of 340B compliance. Tune in for her practical insights, guidance, and lively discussions on all things 340B.
00:00:00.017 --> 00:00:05.737
Welcome to the 340 Banter Podcast. In today's episode, we'll be discussing entity-owned pharmacies.
00:00:06.477 --> 00:00:11.297
Recently, many covered entities have wanted to investigate opening an entity-owned
00:00:11.297 --> 00:00:12.997
pharmacy, but don't know where to start.
00:00:13.577 --> 00:00:16.957
We'll discuss what you should think about before you open a pharmacy,
00:00:17.157 --> 00:00:19.937
as well as tips to help it succeed once it is opened.
00:00:39.577 --> 00:00:43.197
You know, with all the manufacturer restrictions we've been seeing around contract
00:00:43.197 --> 00:00:48.837
pharmacies, we've really seen covered entities take a significant hit to their 340B savings.
00:00:48.837 --> 00:00:54.597
And it's really impacted patient care with layoffs and different service lines
00:00:54.597 --> 00:00:55.737
needing to be trimmed down.
00:00:55.997 --> 00:01:01.577
And one of the things that we're seeing a lot is covered entities look to entity-owned
00:01:01.577 --> 00:01:04.137
or in-house pharmacies, either starting a new one,
00:01:04.517 --> 00:01:08.937
adding to an existing one, or optimizing ones that they already have to try
00:01:08.937 --> 00:01:11.477
to make the most of the 340B savings within there.
00:01:11.797 --> 00:01:16.177
Logan, working within our pharmacy services service line, I was wondering if
00:01:16.177 --> 00:01:20.577
you could kind of talk to us about what you're seeing as you're walking health
00:01:20.577 --> 00:01:22.737
centers through adding their own in-house pharmacy.
00:01:22.737 --> 00:01:29.737
Yeah, I really think it's become a very popular service line.
00:01:29.857 --> 00:01:34.577
We're having more and more people come to us asking us if it's possible.
00:01:34.577 --> 00:01:36.317
And I think that that's the first step.
00:01:36.657 --> 00:01:40.697
Is an entity-owned pharmacy ripe for every covered entity?
00:01:40.877 --> 00:01:45.537
Probably not. But unfortunately, I know it's really hurting some of the smaller
00:01:45.537 --> 00:01:50.597
FQHCs, but you have to have that volume of prescriptions to really make it valuable.
00:01:50.597 --> 00:01:57.037
But we're talking to health centers all over the country that are really seeking
00:01:57.037 --> 00:01:58.157
to see if it's right for them.
00:01:58.717 --> 00:02:02.597
What are things, aside from having a smaller organization with just smaller
00:02:02.597 --> 00:02:07.517
script volume in general, what are other things that might contribute to an
00:02:07.517 --> 00:02:09.957
entity-owned pharmacy maybe not being the right thing?
00:02:10.364 --> 00:02:14.064
Pick for a certain organization. I think the other thing is paramix.
00:02:14.864 --> 00:02:20.104
So we commonly, when we're looking at that, we're pulling for health centers,
00:02:20.224 --> 00:02:25.324
we're pulling UDS data because we can pull that paramix right off of HRSA's website.
00:02:26.064 --> 00:02:29.464
Hospitals would have the same stuff in their cost reports as well. Exactly.
00:02:30.084 --> 00:02:33.164
So it's important to know that for a couple reasons.
00:02:33.684 --> 00:02:36.904
One, you're going to want to know how many unassured patients you're going to
00:02:36.904 --> 00:02:38.964
have because really we're not
00:02:38.964 --> 00:02:43.284
making money on our uninsured patients were there to provide a service.
00:02:43.524 --> 00:02:50.744
And the goal is to break even, maybe pay for the time of the pharmacist to dispense that prescription.
00:02:50.984 --> 00:02:56.604
But even some health centers don't do that. They subsidize that cost for their uninsured patients.
00:02:56.744 --> 00:03:00.124
But that makes a burden on the health center financially.
00:03:00.524 --> 00:03:04.984
The other thing is really knowing the Medicaid rules in your specific state.
00:03:05.284 --> 00:03:12.364
Some states, like mine of Ohio, we preserve our 340B savings on our managed care Medicaid claims.
00:03:12.364 --> 00:03:18.224
So it allows us to be reimbursed at a level where we still maintain those savings.
00:03:18.844 --> 00:03:24.064
Where what we're seeing in a lot of states is that even managed care Medicaid
00:03:24.064 --> 00:03:26.924
is being reimbursed at a fee-for-service logic.
00:03:27.024 --> 00:03:32.064
And that's the acquisition cost of the drug plus a professional dispensing fee.
00:03:32.264 --> 00:03:38.144
And while that's pretty much a break-even, which isn't bad, but it makes it
00:03:38.144 --> 00:03:43.424
hard if you have a very high Medicaid percentage to keep the pharmacy sustainable.
00:03:43.624 --> 00:03:47.644
Doesn't give you a lot of buffer room. Also, I feel like, you know, not all states',
00:03:48.204 --> 00:03:52.744
professional dispensing fee is equivalent to the overhead, you know,
00:03:52.844 --> 00:03:57.144
the admin fee that you typically would assign to a prescription at just as part
00:03:57.144 --> 00:03:59.104
of your usual and customary billing in the pharmacy.
00:03:59.104 --> 00:04:03.524
The cost of billing a bottle of air is typically higher.
00:04:03.944 --> 00:04:08.444
Another thing, too, is that even if you're a small health center,
00:04:08.564 --> 00:04:10.364
it doesn't mean that the pharmacy is not right for you, right?
00:04:10.744 --> 00:04:13.824
Now, is it more likely that it may not be for you?
00:04:13.924 --> 00:04:17.764
Yes, but based on your, you know, we kind of talked based on your payers from
00:04:17.764 --> 00:04:22.424
a perspective of it not being financially viable.
00:04:23.084 --> 00:04:26.504
Also, based on your payers, we can find that it is financially viable at a small
00:04:26.504 --> 00:04:31.704
health center. In addition to the payers, it's also what specialties you have.
00:04:31.964 --> 00:04:37.904
Because some specialties come with just drugs that typically have a higher 340B savings.
00:04:38.184 --> 00:04:43.264
So if you have just primary care, it may be a little challenging if they're
00:04:43.264 --> 00:04:45.524
pretty much dispensing generic medication.
00:04:45.884 --> 00:04:51.644
But if you're doing HIV care, you may be able to sustain a program,
00:04:52.004 --> 00:04:55.324
a pharmacy program, with less prescription volume. them.
00:04:55.898 --> 00:05:00.778
The thing I think that's really cool there is that that becomes kind of mutually sustainable.
00:05:01.438 --> 00:05:08.738
So your specialties where the medications associated with them might have a larger 340B savings.
00:05:08.738 --> 00:05:14.558
That then helps the organization reinvest in treating that condition or that
00:05:14.558 --> 00:05:17.758
disease state or adding in services for another one.
00:05:17.878 --> 00:05:22.298
So we've seen a lot of organizations through their 340B programs and through
00:05:22.298 --> 00:05:25.938
the savings generated just from their entity-owned pharmacy be able to add things
00:05:25.938 --> 00:05:31.998
like hepatitis C treatment or HIV treatment or more mental health,
00:05:32.118 --> 00:05:35.638
excuse me, more mental health services or homeless, you know,
00:05:35.718 --> 00:05:36.938
homeless shelter or health care.
00:05:37.098 --> 00:05:41.298
And so I think that, you know, those drive the prescriptions that might help
00:05:41.298 --> 00:05:44.198
the organization increase 340B savings.
00:05:44.198 --> 00:05:49.478
And then that 340B savings is often directly invested right back into expanding
00:05:49.478 --> 00:05:54.018
access to care that's really hard to get, particularly in some rural areas.
00:05:54.158 --> 00:05:58.518
We're seeing a lot of health centers also, you mentioned hepatitis C.
00:05:59.038 --> 00:06:03.618
We're seeing health centers be able to start clinical pharmacy interventions
00:06:03.618 --> 00:06:09.758
as well through that because clinical pharmacy services aren't always reimbursable.
00:06:09.898 --> 00:06:13.238
So that's a great way to use your 340B savings.
00:06:13.298 --> 00:06:20.058
And it's a symbiotic relationship. So once you start a clinical pharmacy program
00:06:20.058 --> 00:06:24.598
that's getting hepatitis C treatment out there, one, it's great clinically because
00:06:24.598 --> 00:06:27.818
you're curing a viral disease for the patient.
00:06:28.038 --> 00:06:33.858
You're curing it. And two, it's creating more and more 340B revenue,
00:06:33.858 --> 00:06:36.098
which allows you to keep funding those services.
00:06:36.298 --> 00:06:41.698
And even outside of specialty, I think clinical pharmacy brings a lot of value and has that, you know,
00:06:42.251 --> 00:06:46.231
a mutual connected relationship with the in-house pharmacy. The more my patient
00:06:46.231 --> 00:06:49.651
gets familiar with our pharmacy team, you know, we see a lot of health centers
00:06:49.651 --> 00:06:53.071
will, will kind of rotate where, you know, you have certain days you work in
00:06:53.071 --> 00:06:55.671
the pharmacy, certain days you work on the clinical side.
00:06:56.071 --> 00:06:59.731
And, you know, not that we're, you don't steer prescriptions,
00:06:59.731 --> 00:07:04.951
you're not trying to steer a prescription, but the, the patient is more involved with your team now.
00:07:05.091 --> 00:07:09.111
And so the likelihood of them, you know, if they see your pharmacist on the
00:07:09.111 --> 00:07:11.931
clinical side and then, you know, next week, I'm going to be able to see them
00:07:11.931 --> 00:07:14.151
inside the pharmacy when I pick up my medication.
00:07:14.571 --> 00:07:18.591
I think you have a likelihood of higher capture rate. Yeah. And just.
00:07:18.731 --> 00:07:20.151
Increased level of trust. Right.
00:07:20.711 --> 00:07:24.291
And along with the steering, I think that that's a good point.
00:07:24.391 --> 00:07:26.391
Or lack of. Or lack of steering.
00:07:26.611 --> 00:07:32.871
That discussion, I think it's a good point to discuss because that scares a lot of health centers.
00:07:33.271 --> 00:07:38.031
Because you're not prohibited to steer your patient's prescriptions to your
00:07:38.031 --> 00:07:38.951
entity-owned pharmacy.
00:07:38.951 --> 00:07:46.871
But I think it's important to take a step back, think about pharmacy the way
00:07:46.871 --> 00:07:48.551
you think about every other specialty.
00:07:48.551 --> 00:07:52.291
Can I, sorry, I want to revisit because I think you said you're not prohibited
00:07:52.291 --> 00:07:57.971
from steering your patients to your own pharmacy and you don't want to remove,
00:07:58.211 --> 00:08:02.371
we're not saying that you're removing the patient's choice in where to fill
00:08:02.371 --> 00:08:04.211
their prescription as opposed to steering.
00:08:04.431 --> 00:08:08.491
We're more providing education about the additional services and level of care
00:08:08.491 --> 00:08:09.791
they would get from your pharmacy.
00:08:10.331 --> 00:08:15.991
Sorry, I just wanted to. Take us off the rails here, Logan. So I think I think
00:08:15.991 --> 00:08:21.031
they're if you think about it as another specialty our providers are not.
00:08:21.690 --> 00:08:25.570
Concerned with recommending a cardiologist that works really well with them
00:08:25.570 --> 00:08:27.270
that they have a good relationship with.
00:08:27.510 --> 00:08:30.030
Does the patient have to use that cardiologist? No.
00:08:30.290 --> 00:08:34.250
They can go to a different cardiologist. They can say, I want to use this other
00:08:34.250 --> 00:08:37.410
cardiologist, but that's not considered steering.
00:08:37.930 --> 00:08:45.270
That's explaining a clinical benefit and a communication benefit to using that cardiologist.
00:08:45.470 --> 00:08:47.250
I think the same goes for pharmacy.
00:08:47.570 --> 00:08:52.410
Your medical providers have a lot of trust with their patients so they can communicate
00:08:52.410 --> 00:08:58.650
that and say, these are the clinical benefits to using our entity-owned pharmacy.
00:08:58.810 --> 00:09:03.310
I think that point is a great one to build on because we talked about the benefit
00:09:03.310 --> 00:09:08.450
from the 340B savings, reestablishing those 340B savings within an entity-owned
00:09:08.450 --> 00:09:12.370
pharmacy, particularly if you're feeling that loss from the contract pharmacy restrictions.
00:09:12.550 --> 00:09:16.170
But there are so many benefits to entity-owned pharmacies
00:09:16.170 --> 00:09:19.190
outside of just the 340B savings and
00:09:19.190 --> 00:09:22.450
the financial aspects and i think it's worth discussing some
00:09:22.450 --> 00:09:25.730
of those because that can help the the decision
00:09:25.730 --> 00:09:28.570
making process on if an entity-owned pharmacy is right
00:09:28.570 --> 00:09:31.470
for a certain organization yeah and
00:09:31.470 --> 00:09:34.170
i think that kind of you know the start of
00:09:34.170 --> 00:09:36.990
that is is more of a family setting almost right because like
00:09:36.990 --> 00:09:40.030
rather than i'm going to see this corporation and then
00:09:40.030 --> 00:09:45.550
i have to go get this at this corporation when it's all in one family you know
00:09:45.550 --> 00:09:50.470
leadership is the same they should be operate not necessarily operating but
00:09:50.470 --> 00:09:55.130
the way they do business should be the same you know the mindset of of what
00:09:55.130 --> 00:09:58.410
we stand behind you know how we're going to provide our support.
00:09:59.110 --> 00:10:02.710
And not that independence you know independence do a great job at supporting
00:10:02.710 --> 00:10:08.090
their patients and the community but it just it makes everything a little bit
00:10:08.090 --> 00:10:12.650
simpler so yeah and i know you know i think you're caveating more of.
00:10:13.264 --> 00:10:16.304
I don't know if caveating is the right word, but you're going more into the
00:10:16.304 --> 00:10:20.044
patient care side because there's benefits from just patient care.
00:10:20.204 --> 00:10:25.384
But I think just from a personal relationship side, it's better to deal with one entity.
00:10:25.624 --> 00:10:28.204
It just feels more homey. You know, I don't know if that makes sense.
00:10:28.204 --> 00:10:34.784
I mean, I'll say from the patient care side and the better connection side of things,
00:10:35.024 --> 00:10:40.344
by the pure nature of being in the same building as the health center in many
00:10:40.344 --> 00:10:46.304
cases and having access to the same medical record, it streamlines so much.
00:10:46.304 --> 00:10:52.144
Having worked as a retail pharmacist, both in pharmacy within my FQHC and also
00:10:52.144 --> 00:10:54.904
in a retail pharmacy outside of the FQHC,
00:10:55.164 --> 00:11:00.664
having to correct a prescription or call about dosing to clarify something or
00:11:00.664 --> 00:11:04.724
needing to change a prescription because we have information about an allergy
00:11:04.724 --> 00:11:06.704
that maybe the physician didn't have.
00:11:06.704 --> 00:11:10.584
Being in the health center makes that so much more seamless.
00:11:11.164 --> 00:11:15.224
Just from the pharmacist workflow point of view, but also from the patient's
00:11:15.224 --> 00:11:18.544
point of view, it's so frustrating as a patient when you're already sick,
00:11:18.684 --> 00:11:22.724
already having a really bad day, go to a pharmacy and they say,
00:11:22.904 --> 00:11:24.084
you know, there's a problem with the prescription.
00:11:24.224 --> 00:11:29.444
We have to talk to your provider. And then it takes them two days to get clarification and get that back.
00:11:29.504 --> 00:11:32.484
And you're already feeling terrible. You're already having to drive to multiple
00:11:32.484 --> 00:11:35.564
places, what have you, not in the medication when you need to be.
00:11:35.564 --> 00:11:41.304
And in the pharmacy attached to the health center, you can call the provider's MA.
00:11:41.984 --> 00:11:45.144
That's right down the hall. You can go check in the medical record to see what
00:11:45.144 --> 00:11:46.524
they discussed during the visit.
00:11:46.624 --> 00:11:51.264
Maybe there was a reason for choosing this specific thing, even though there's a documented allergy.
00:11:51.484 --> 00:11:54.784
They talked more about what the reaction was and this medication's okay now.
00:11:55.084 --> 00:11:59.424
Or I could just go down the hall and ask them, grab them on their way out of
00:11:59.424 --> 00:12:02.764
their pod, from their desk or on their way into a visit. Hey,
00:12:02.844 --> 00:12:04.424
can I clarify a prescription real quick?
00:12:05.054 --> 00:12:08.394
And we're able to help that patient before they've left the building the first
00:12:08.394 --> 00:12:10.434
time and actually get that taken care of.
00:12:10.454 --> 00:12:14.494
I would stand outside the exam room until they came out and catch them.
00:12:14.754 --> 00:12:19.034
Another benefit, especially to health centers, and I'm sure it applies to the
00:12:19.034 --> 00:12:24.074
hospital space as well, are your value-based care agreements.
00:12:24.334 --> 00:12:28.394
That's becoming more and more important for health centers is that you're being
00:12:28.394 --> 00:12:31.754
paid in a different manner instead of a fee-for-service logic.
00:12:31.754 --> 00:12:33.574
You're getting paid based on performance.
00:12:33.794 --> 00:12:40.294
And almost every one of those measures is directly or indirectly impacted by pharmacy care.
00:12:40.434 --> 00:12:45.854
So by getting a patient adherent on something like their statins,
00:12:46.314 --> 00:12:50.934
it's going to decrease their risk for heart attack or stroke.
00:12:51.154 --> 00:12:57.494
And by really putting a focus on that entity on pharmacy, you're going to increase
00:12:57.494 --> 00:13:01.274
adherence to drugs and have better patient care,
00:13:01.554 --> 00:13:06.994
and that will indirectly provide more revenue for the health center by improving
00:13:06.994 --> 00:13:08.314
those performance measures. Right.
00:13:08.474 --> 00:13:14.094
And then, you know, pharmacy is the retail side of pharmacy is not what it used to be.
00:13:14.354 --> 00:13:17.514
It's very difficult. And so if we look at it from a business model,
00:13:17.774 --> 00:13:21.334
because of 340 being an in-house pharmacy.
00:13:22.276 --> 00:13:25.236
W we essentially have more time to spend with the patient right
00:13:25.236 --> 00:13:28.276
our pharmacists have more time to to interact with that patient
00:13:28.276 --> 00:13:31.236
because independent retail pharmacy is a
00:13:31.236 --> 00:13:35.036
very tough game right they have to squeeze every penny out of everything they
00:13:35.036 --> 00:13:39.856
can get now that i'm not you know they love their communities they go above
00:13:39.856 --> 00:13:45.116
and beyond for their patients but at the same time they also have to make business
00:13:45.116 --> 00:13:48.756
sense they have to be able to pay their salaries they have to be able to pay their overhead,
00:13:48.936 --> 00:13:52.996
they don't get federal grants to help supplement that like the FQs do.
00:13:53.296 --> 00:13:56.736
But even those grants are really for the medical side.
00:13:56.816 --> 00:14:02.456
So the 340B allows us to spend more time inside that pharmacy and get those
00:14:02.456 --> 00:14:05.416
interactions with those patients and make them feel comfortable with us.
00:14:05.556 --> 00:14:07.956
And the contract pharmacy restrictions are hitting them too.
00:14:08.176 --> 00:14:12.656
So it's not just the impact to the covered entity, but it's also the impact
00:14:12.656 --> 00:14:14.456
to our partner pharmacies.
00:14:14.976 --> 00:14:18.876
So they're getting hit from another direction now.
00:14:19.136 --> 00:14:27.456
And I just think that that's somewhere where we're able to help those more complex patients.
00:14:27.796 --> 00:14:32.596
One of the things, one of my providers, it took her a while to get on board
00:14:32.596 --> 00:14:35.196
with entity-owned pharmacy when I was at my health center.
00:14:35.716 --> 00:14:41.376
But one of the things that really spoke to her was that we were helping her
00:14:41.376 --> 00:14:43.356
patients when there was an access issue.
00:14:43.356 --> 00:14:46.316
So maybe it was insurance wasn't covered or
00:14:46.316 --> 00:14:49.256
it needed prior authorization and she said i don't
00:14:49.256 --> 00:14:52.636
know how many of my patients when they walk out the door don't fill
00:14:52.636 --> 00:14:56.176
their prescription yeah and that they can
00:14:56.176 --> 00:15:01.416
help if they know but they don't know right and that was a huge benefit for
00:15:01.416 --> 00:15:04.516
and really sold her on the entity-owned pharmacy i think one of the other cool
00:15:04.516 --> 00:15:08.896
things that you can do facilitating when you have or that you can facilitate
00:15:08.896 --> 00:15:13.496
when you have your entity-owned pharmacy is prescription assistance programs
00:15:13.496 --> 00:15:15.276
and those bulk replenishment medications.
00:15:16.217 --> 00:15:19.477
If you send a patient out for a prescription, they go to, you know,
00:15:19.617 --> 00:15:23.397
a retail pharmacy out in the community, can't afford it, and they come back
00:15:23.397 --> 00:15:25.537
to you and say, I can't afford this medication.
00:15:25.877 --> 00:15:29.797
There are access navigators within the health center who can help them look
00:15:29.797 --> 00:15:31.577
into the prescription assistance programs.
00:15:31.737 --> 00:15:34.997
But again, that's an additional delay in care, and it relies on the patient
00:15:34.997 --> 00:15:37.197
coming back and asking for help.
00:15:37.197 --> 00:15:42.417
Versus if you are managing it within your own entity-owned pharmacy and you
00:15:42.417 --> 00:15:48.257
have the ability to contract with some of the prescription assistance bulk replenishment programs,
00:15:48.417 --> 00:15:52.177
once you qualify patients for those, they can come get those prescriptions for
00:15:52.177 --> 00:15:54.977
free from your pharmacy just like everyone else.
00:15:54.977 --> 00:15:58.157
They're not waiting to get things in the mail. You're not relying on the patient
00:15:58.157 --> 00:16:03.457
to come back to the health center and seek out additional support in getting
00:16:03.457 --> 00:16:04.897
affordable medication.
00:16:04.897 --> 00:16:08.797
So it's really nice to be able to pull that in, take away any stigma from having
00:16:08.797 --> 00:16:14.357
to go through a different access point, take away an additional barrier to receiving
00:16:14.357 --> 00:16:17.397
care by letting them get it at the pharmacy just like they would otherwise.
00:16:17.737 --> 00:16:23.537
The same thing with vaccines, increase a lot of access to vaccine care in general
00:16:23.537 --> 00:16:26.117
when the pharmacists are able to provide them.
00:16:26.297 --> 00:16:30.457
Particularly, I know in cold and flu season, our walk-in clinic would just get
00:16:30.457 --> 00:16:34.077
slammed with vaccine requests, which was great.
00:16:34.077 --> 00:16:40.157
You want your community vaccinated to protect, but we just, a lot of times our
00:16:40.157 --> 00:16:42.577
health center staff didn't have the capacity for it.
00:16:42.677 --> 00:16:46.677
And being able to increase that capacity within the pharmacy so they're still
00:16:46.677 --> 00:16:49.637
in the same building, you're not sending them away somewhere else.
00:16:50.077 --> 00:16:53.817
Being able to do that was very meaningful, I know, for us. Another opportunity
00:16:53.817 --> 00:16:55.497
could be pharmacy students.
00:16:55.777 --> 00:17:00.697
It gives you the opportunity as a pharmacist to be a preceptor for pharmacy
00:17:00.697 --> 00:17:05.217
students in their final year of school, and that brings an extra person into the health center.
00:17:05.357 --> 00:17:09.657
That person can immunize, that person can work through the different pharmacy things.
00:17:09.697 --> 00:17:13.677
It doesn't mean it's free labor because it's some work on the preceptor. It is a lot of work.
00:17:14.717 --> 00:17:21.177
But it does allow you to expand your services, and students are a great way
00:17:21.177 --> 00:17:23.117
to bring fresh eyes into your pharmacy.
00:17:23.657 --> 00:17:28.197
I think we've talked a lot about the kind of the decision points that might
00:17:28.197 --> 00:17:31.497
help you get to is an entity-owned pharmacy right for your organization?
00:17:31.737 --> 00:17:36.377
And then what additional value and benefits can you derive from having your
00:17:36.377 --> 00:17:37.437
own entity-owned pharmacy?
00:17:37.637 --> 00:17:42.617
And I'd love if we could kind of wrap the conversation up by just touching on
00:17:42.617 --> 00:17:48.377
what conversation points or what partners you need within the leadership,
00:17:48.597 --> 00:17:52.957
the organizational leadership, to move an entity-owned pharmacy forward because
00:17:52.957 --> 00:17:56.877
it is not a pharmacy-specific, you know, it's not in a silo.
00:17:57.377 --> 00:18:00.957
There's so many other parts of the health care system in the health center that,
00:18:01.670 --> 00:18:04.910
play into that. So maybe you could talk a little bit about, particularly because
00:18:04.910 --> 00:18:09.310
you come from a background outside of pharmacy, how important those conversations
00:18:09.310 --> 00:18:12.990
are in discussing the viability for an entity-owned pharmacy.
00:18:13.290 --> 00:18:18.870
Yeah, even past viability, it's like, how do you maintain it as someone who
00:18:18.870 --> 00:18:22.070
doesn't understand pharmacy and how it operates?
00:18:23.010 --> 00:18:26.610
I think one of the big things that I see is,
00:18:26.750 --> 00:18:30.250
and again, this is just because that's where my best understanding is,
00:18:30.270 --> 00:18:33.030
is the accounting side yeah so you know when we go into
00:18:33.030 --> 00:18:36.230
house pharmacies and you know there's like
00:18:36.230 --> 00:18:39.150
there's almost a disconnect and i feel
00:18:39.150 --> 00:18:42.510
like we've had conversations about this before where sometimes you go into a
00:18:42.510 --> 00:18:47.770
health center and it's almost though they're the same it's almost like they're
00:18:47.770 --> 00:18:51.290
separate entities right like the pharmacy exists over here they're in the same
00:18:51.290 --> 00:18:55.790
building you know same employer same management however like they have their
00:18:55.790 --> 00:18:57.930
own thing and then medical has their own thing.
00:18:58.310 --> 00:19:02.050
And I think that from a management perspective, you want to put things in place
00:19:02.050 --> 00:19:03.310
to kind of bridge that gap.
00:19:03.710 --> 00:19:08.710
And that could be different committees that you set up to have those interactions between departments.
00:19:09.770 --> 00:19:13.050
But like my big thing is the accounting. The accounting is kind of a mess.
00:19:13.610 --> 00:19:16.250
And, you know, I've gone into some health centers where they're like,
00:19:16.390 --> 00:19:20.350
oh, well, we make the pharmacy kind of prepare that for us.
00:19:20.430 --> 00:19:24.550
And I'm like, but that's not what they understand. And that's not what we're paying them to do.
00:19:25.030 --> 00:19:29.210
And, you know, that we're not good at. Right. And so I feel that accounting,
00:19:29.410 --> 00:19:33.250
you know, your accounting department needs to understand how to run a report.
00:19:33.670 --> 00:19:38.570
Again, do they need to know the clinical benefit of this drug versus this drug? Probably not.
00:19:39.530 --> 00:19:44.050
Understand some of the nuances of the 340B program at a high level.
00:19:44.050 --> 00:19:46.410
You need to know some things. You need to know what's allowed.
00:19:46.630 --> 00:19:49.930
You need to be able to catch that. But someone in accounting should know how
00:19:49.930 --> 00:19:54.850
to run a report out of the filling system and be able to take that and understand
00:19:54.850 --> 00:19:56.110
what the data is telling them. Right.
00:19:56.430 --> 00:20:02.510
And further than that, not just understanding what it's trying to tell me, understanding when...
00:20:03.030 --> 00:20:06.350
It's not right. Like, and that's a hard thing. You don't know because you,
00:20:06.590 --> 00:20:11.130
in accounting, we're used to trusting numbers and what numbers come out of the system come out.
00:20:11.930 --> 00:20:16.870
But for some reason, pharmacy filling softwares and accounting departments kind
00:20:16.870 --> 00:20:18.310
of butt heads quite a bit.
00:20:18.390 --> 00:20:22.330
So I think it's super important for your finance team to understand that so
00:20:22.330 --> 00:20:25.250
that you're not having problems at year end when you have your single audit
00:20:25.250 --> 00:20:28.870
come in and, you know, and, and, well, I don't know why it says that number.
00:20:29.050 --> 00:20:31.790
That's what the system told me. You need to understand that,
00:20:31.890 --> 00:20:33.430
hey, that's probably not the right number.
00:20:33.590 --> 00:20:38.050
You need to have enough understanding of your pharmacy as management to be able
00:20:38.050 --> 00:20:40.330
to get a report and say, that doesn't seem right.
00:20:40.590 --> 00:20:44.510
I think that that's really important when you are starting up an entity-owned
00:20:44.510 --> 00:20:48.350
pharmacy so that you have that understanding and you're building a solid base.
00:20:48.350 --> 00:20:52.590
But I think it's so important, even once the pharmacy is up and running and
00:20:52.590 --> 00:20:56.410
having your finance team understand, like I said, that, you know,
00:20:56.550 --> 00:21:00.750
a little bit of how the 340B program works and how the different pieces interplay.
00:21:01.010 --> 00:21:05.430
Because I know that I've definitely had to deal with the perception of the 340B
00:21:05.430 --> 00:21:08.970
program or the pharmacy program being like the goose that lays the golden eggs.
00:21:09.130 --> 00:21:13.410
And like, oh, well, this has helped because honestly, health centers typically
00:21:13.410 --> 00:21:17.970
would operate in the negative without their 340B program. Absolutely.
00:21:18.250 --> 00:21:22.270
And because of that, each year coming back and saying, OK, well, we had this.
00:21:22.390 --> 00:21:25.290
We need to add this service next year. So we're going to need your department
00:21:25.290 --> 00:21:26.870
to make this much more money.
00:21:27.010 --> 00:21:30.890
And having to then tie it back to, you know, you said accountants trust numbers.
00:21:31.090 --> 00:21:33.430
So bring it back to, OK, here's how many visits we have.
00:21:33.650 --> 00:21:36.250
Here's how many prescriptions we generate out of a visit.
00:21:36.730 --> 00:21:39.990
Here's how many prescriptions we're capturing out of our, you know, in our pharmacy.
00:21:40.410 --> 00:21:44.130
Realistically, this is about what we can capture.
00:21:44.290 --> 00:21:47.270
And this isn't it's not going to infinitely grow, you know.
00:21:47.270 --> 00:21:52.690
And being able to connect those dots and have your finance team,
00:21:53.050 --> 00:21:58.850
your budgeting team understand that moving forward as well so that you're having
00:21:58.850 --> 00:22:02.050
realistic expectations within your pharmacy is really important too.
00:22:02.050 --> 00:22:08.410
I think thinking about that whole leadership approach, one of the things when
00:22:08.410 --> 00:22:13.430
I've talked to C-suite, especially when they're new to pharmacy,
00:22:13.870 --> 00:22:18.290
either getting implementation going or they just opened a pharmacy,
00:22:18.290 --> 00:22:20.490
or maybe that they're struggling.
00:22:20.490 --> 00:22:22.870
They've had one for a while and their pharmacy is struggling.
00:22:23.230 --> 00:22:28.470
One of the things I like to tell the C-suite is the pharmacy staff are the least
00:22:28.470 --> 00:22:32.050
impactful on the capture rate. Can they be impactful? Yeah.
00:22:32.390 --> 00:22:38.390
If they're giving poor service to their patients, then it's going to negatively impact it.
00:22:38.570 --> 00:22:43.750
But really the most important piece in most health centers, at least,
00:22:43.870 --> 00:22:48.630
and I'm sure this applies to other covered entity types, is that medical provider.
00:22:49.391 --> 00:22:52.651
They've developed that rapport, that trust with the patient,
00:22:52.651 --> 00:22:55.671
and they follow their recommendations.
00:22:56.071 --> 00:23:01.791
So if they're talking about the pharmacy, then it's going to succeed.
00:23:02.191 --> 00:23:04.971
But really, it needs to be an all-staff approach.
00:23:05.811 --> 00:23:10.751
Again, it's a trickle-down thing, right? So you need C-suites buy-in.
00:23:11.051 --> 00:23:15.951
You got to have it. Because if you have C-suites buy-in, they can help you get medicals buy-in.
00:23:16.071 --> 00:23:19.051
If you don't have C-suites buy-in, you have a problem.
00:23:19.931 --> 00:23:26.431
And especially for an FQ, right, we get federal funding because we provide services
00:23:26.431 --> 00:23:30.691
that are expensive for us to provide, knowing that we may be serving patients
00:23:30.691 --> 00:23:34.131
who don't have an ability to pay the expensive cost. So we're writing that down.
00:23:34.491 --> 00:23:39.971
And so in the pharmacy is really one of the, there's a few, but one of the only
00:23:39.971 --> 00:23:47.891
areas where you can typically generate income or profit versus medical or dental or behavioral health.
00:23:47.891 --> 00:23:54.551
And so to me, it just would make, I think everyone from the C-suite should buy in, right?
00:23:54.691 --> 00:23:58.271
Because this is an area where we can, and we should show it some love and we
00:23:58.271 --> 00:24:02.991
should show some, you know, we should be observing this and have discussions
00:24:02.991 --> 00:24:08.111
around what's going on in the pharmacy and fine tuning that pharmacy to operate efficiently.
00:24:08.111 --> 00:24:12.651
Because by operating efficiently, one, you know, from a business perspective,
00:24:12.871 --> 00:24:17.271
you were able to produce income, but two, you're getting better patient care.
00:24:17.451 --> 00:24:23.491
I mean, the more efficient we can be in any workflow, we get to produce a better product, right?
00:24:23.711 --> 00:24:26.171
Yeah. So, I mean, so you're pulling in, we already talked about finance.
00:24:26.171 --> 00:24:27.611
You talked about clinical leadership.
00:24:27.971 --> 00:24:32.511
You've also got quality, you know, the quality of your patient care and meeting
00:24:32.511 --> 00:24:33.991
your value-based measures.
00:24:33.991 --> 00:24:37.051
We've got compliance and legal because
00:24:37.051 --> 00:24:40.791
of the nature of a government program i
00:24:40.791 --> 00:24:44.171
i think that it touches so many different aspects of
00:24:44.171 --> 00:24:47.091
the of the covered entity of the health system that that
00:24:47.091 --> 00:24:50.011
buying is really important and so education is really important because
00:24:50.011 --> 00:24:53.111
you don't get buy-in without people understanding so i think yeah if
00:24:53.111 --> 00:24:56.211
we were to pick kind of the one major major thing to
00:24:56.211 --> 00:24:59.271
deliver to your organization if you're
00:24:59.271 --> 00:25:03.191
thinking about an entity on farms you'd probably be educating and
00:25:03.191 --> 00:25:06.691
talking with your c-suite and understanding what what values
00:25:06.691 --> 00:25:10.031
they have that a pharmacy absolutely absolutely i
00:25:10.031 --> 00:25:15.311
i agree completely that that education component one of the things when we're
00:25:15.311 --> 00:25:18.951
talking to people who've just opened a pharmacy because they're they're trying
00:25:18.951 --> 00:25:25.151
to grow their their pharmacy business is try to get included in orientation
00:25:25.151 --> 00:25:28.611
So you talk to every provider when they come on staff.
00:25:28.771 --> 00:25:31.351
So they understand how the 340B
00:25:31.351 --> 00:25:34.411
program works. So they understand how the entity-owned pharmacy works.
00:25:34.811 --> 00:25:39.291
Because the better they know how it works, the more engaged they're going to be.
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