Written By: Rich Bucher
While implementing referral capture strategies can potentially lead to significant 340B savings for your 340B covered entity (CE), it is important to remember that you, the CE, remain responsible for ensuring full compliance. Managing a fully compliant and cost-effective referral process will require diligence and resources, despite what some third-party vendors or others may tell you. The old proverb “You don’t get something for nothing” applies here. For this reason, it is important for you to first take steps to estimate the potential benefit that implementing such a strategy will provide and then compare the estimated benefit to the cost/resources that it will take to maintain full compliance (cost/risk vs. benefit analysis). For the potential benefit, the reality is every CE is unique with respect to its particular mix of prescribers, types of clinics and healthcare services, drugs prescribed to its patients, and retail pharmacies where prescriptions are filled. All these factors will influence the cost to you that will offset the 340B savings benefit you receive.
Don’t rely on data that is not specific to your CE or that is not comprehensive. When reviewing filled prescription data, work with your third-party administrator (TPA) vendor(s) to determine which prescriptions are accessible for review since those that were not qualified (but potentially could be) is key. In addition to prescription data and operational costs, it is important to also account for the specific expenses associated with internal oversight and auditing.
While third-party referral capture vendors can play an important part as partners to CEs in their referral capture processes, there is simply no substitute for the CE itself proactively maintaining responsibility for compliance and financial oversight. Each CE must maintain a clear understanding of each step in the process and the specific role that its vendor(s) play. Miscommunication with vendors about responsibilities or complacency with respect to internally confirming ongoing compliance and operational efficiency can lead to disastrous results.
Have you already implemented a referral capture process or are you considering it? Do you want a 340B partner with extensive 340B experience and expertise that you can trust? SpendMend Pharmacy’s Referral Capture program focuses first and foremost on full compliance, while also optimizing the 340B savings available to you. Learn more at: