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DescriptionSHIFT: No Weekends
The Market 340B Program Director is responsible for developing the strategy, vision, and business plans for facilities in the St. David’s Healthcare Partnership (SDHP) that participate in or may be eligible to participate in the 340B Drug Discount Program. This role is accountable for managing and improving the design, development, implementation, and maintenance of the SDHP 340B Programs. The Market 340B Program Director will lead, plan, direct, and coordinate the business operations of the 340B Programs for the SDHP.
The Market 340B Program Director monitors regulatory requirements, guidelines, and program changes and is accountable for maintaining a compliant 340B Program. The role has accountability for fostering effective working relationships for 340B staff with business functions outside of pharmacy including supply chain, finance, legal, compliance, IT, and external vendors. In addition, the position provides guidance for 340B Program education and training of stakeholders, associated leaders, and staff.
Division Director of Pharmacy Services
Market 340B Program Coordinator
Division Pharmacy leadership, Chief Financial Officers, Chief Operating Officers, Directors of Pharmacy, 340B Program Coordinators, Pharmacy Buyers, Supply Chain leadership, 340B vendors
· Provides 340B Program leadership and oversight across the health system.
· Supports 340B Program implementation, maintenance, and viability across all covered entities.
· Serves as the leader of the 340B Program Operations Team for the SDHP.
· Serves as an integral member of the Market 340B Steering Committee.
· Serves as the 340B Program compliance expert related to policies, procedures, and best practices for SDHP.
· Acts as the liaison with necessary affiliated departments (i.e., compliance, legal, finance, IT, pharmacy) to ensure 340B Program integrity.
· Develops and maintains external relationships (Apexus, HRSA, wholesalers, manufacturers, contract pharmacies, vendors, pharmacy benefit managers, third party administrators), as needed.
· Provides ongoing education, training, and communications to all staff (particularly those who work with 340B routinely) regarding the 340B Program operations and compliance.
Policy and Procedure Development:
· Ensures consistent policies and procedures for the 340B Program include all federal and state requirements and guidelines, and promotes overall program efficiency and productivity
· Ensures annual HRSA recertification is completed within the allowable timeframe for all covered entities.
· Assists with the registration of any new child sites within the allowable timeframe.
o Confirms all elements of eligibility are met prior to registering new child sites.
· Assists with the termination of 340B programs as needed.
· Monitors and assesses 340B guidance and/or rule changes, including, but not limited to HRSA/OPA rules and Medicaid changes.
o Attends regular 340B training programs, and shares lessons and hot topics with staff.
o Routinely monitors industry publications and websites as well as the professional media, literature, and peers to ensure that the institution has the latest information regarding interpretations, rulings, suggestions, and advanced ideas for improving participation.
· Ensures that all covered entities maintain continuously compliant 340B Programs.
· Provides expertise on all 340B Program legislation and policy changes from HRSA and OPA, informing and collaborating with legal and compliance teams.
Auditing and Monitoring:
· Develops internal auditing processes of the 340B Program at all covered entities.
· Ensures that internal audits follow current regulatory compliance recommendations, and are completed at the facility level.
o Reviews monthly audit results to verify adherence with 340B Program policies and guidelines.
o Coordinates and ensures remediation of findings.
· Reviews and monitors all points of service where 340B participation occurs to ensure policy and procedure compliance, covered entity eligibility, and “covered patient” eligibility.
· Responsible for troubleshooting pharmacy billing issues and ensuring that adequate systems checks are reviewed periodically to prevent billing issues.
· Monitors utilization records and 340B purchasing accounts to ensure that software and/or tools are working properly and accurately, performing audits or compliance assessments internally as needed; coordinates external compliance assessments with outside firms, where appropriate, to validate internal processes.
· Monitors 340B compliance within workflow processes.
· Ensures compliance with all aspects of the 340B Program and implements all applicable aspects of HRSA’s OPA guidance, as well as organizational policies and procedures.
· Ensures evaluations of gaps at the site level and assists in providing the tools necessary to be compliant with the 340B Program.
· Serves as the point person and coordinator for all audits. Coordinates all requests and responses.
· Maintains a current state of “audit readiness.”
· Coordinates external compliance assessments with outside firms, where appropriate, to validate internal processes.
· Notifies HRSA and/or manufacturers as required for diversion.
· Notifies manufacturer if overpayment discovered.
· Assesses opportunities for cost savings and system improvements to yield higher compliance.
· Participates in projects, councils, and special initiatives related to the 340B Program, compliance, auditing functions, vendor selection, and medication management.
· Implements business plans in coordination with organizational pharmacy leadership to help use 340B savings to expand and improve care provided to underserved and vulnerable populations.
· Monitors all outpatient points of service routinely to check for new areas that may qualify for the 340B Program. Provides oversight for the implementation of process improvement initiatives and creates an environment that places an emphasis on continuous monitoring and improvement
· Monitors purchasing records for each 340B covered entity; clearly documents utilization, savings, problem areas, and exceptions or discrepancies. Relays results to pharmacy leadership and administration.
· Monitors 340B pricing exclusions or shortages and establishes appropriate alternative products that are included when possible.
· Routinely reviews 340B formulary pricing, potential alternatives, and possible additional savings as a result of GPO formulary.
· Maintains system databases to reflect changes in the drug formulary or product specifications.
· Tracks, trends, and reports 340B drug sales and purchases to ensure provider/physician and patient eligibility.
· Ensures compliance with regulations related to 340B purchasing.
· Performs thorough quarterly reviews of the new 340B pricing list to search for and quickly address costly changes.
Split-Billing/Third party Administrator Software Maintenance
· Establishes a routine approach to updating the NDC crosswalk for new products and product changes to ensure both the accuracy of the utilization report and the efficiency and accuracy of the charge process.
· Maintains 340B split-billing software integrity and reviews applicable reports to identify areas for improvement.
· Works with the pharmacy informatics team to ensure that the market’s clinical information system is coordinated and integrated with the 340B Program. This shall include the electronic interfaces between the EMR and the virtual accumulator.
· Ensures split-billing software integrity and reviews applicable reports for areas of improvement.
o Oversees split-billing software maintenance
· Participates in the development and implementation of reports generated on the 340B Program that outline savings, utilization, exceptions, and discrepancies.
o Constructs appropriate metrics to review current performance and identify areas for improvement.
o Coordinates monthly financial reporting and analysis, including, but not limited to, metric reporting, scorecards, and variance analysis and reporting.
· Prepares and assists in the monitoring and various tracking and reporting measurements to ensure compliance with the program.
· Routinely monitors monthly and annual reports related to the 340B Program that clearly document utilization, savings, problem areas, and exceptions or discrepancies.
· Routinely communicates any questions, issues, or discrepancies with the appropriate authority.
· Actively participates in Supply Chain Pharmacy Services projects and meetings which may include participating in outside activities and organizations.
· Performs other duties as assigned.
· Practices and adheres to HCA’s “Code of Conduct” philosophy and “Mission and Values Statement”.
· Thorough knowledge of state and federal laws and regulations governing pharmacy services and 340B programs.
· Administrative leadership, and human resource skills required which includes problem solving, conflict management and analytical thinking skills.
· Demonstrates ability to effectively participate and lead interdisciplinary teams and committees.
· Business acumen including profit/loss understanding, contract negotiations, and GPO function required.
· Organization – proactively prioritizes needs and effectively manages resources.
· Communication – Able to communicate (verbal, listening and written) clearly and effectively.
· Leadership – guides individuals and groups toward desired outcomes, setting high performance standards and delivering quality services.
· Customer orientation – establishes and maintains long-term customer relationships, building trust and respect by consistently meeting and exceeding expectations. Able to work with diverse work force.
· Policies and Procedures – articulates knowledge and understanding of organizational policies, procedures and systems.
· Able to work independently and handle stress appropriately.
B.S. or PharmD from an ACPE-accredited School of Pharmacy required. Masters’ Degree in HealthCare Management preferred.
Minimum of 5 years of pharmacy leadership experience preferred. Minimum of 2 years of experience in management of 340B Drug Discount Programs required.
Current pharmacist license in good standing with the appropriate State Board of Pharmacy.
340B Apexus Certification (required within 6 months of start date)