When a covered entity is looking to contract with a third party administrator (TPA), it is critical to approach the conversation as a partnership. A TPA is more than a simple data company that manages your data and then analyzes it through relevant business filters. Because 340B is such a complex program, the relationship needs to be a partnership. Ultimately, for the partnership to work, the TPA needs to be very fluid and proactive in its approach, and at the most basic level, there has to be a strong and transparent collaboration between both parties.
With that in mind, there are several sore spots that most covered entities experience while engaging with a TPA. For instance, one of the most urgent areas of concern is understanding if your data is being handled appropriately. Is your third party administrator consistently applying your customized eligibility filters? Do you have access to all of your data once processed for qualification?
Because many covered entities lack internal resources with the specific knowledge necessary to navigate the litigious requirements of 340B, a high performing TPA can make all the difference in ensuring compliance and maximizing revenue opportunities. Frankly, if there’s no one at your organization who can speak to the 340B program, there is likely a gap in compliance—potentially putting you at significant risk. It may seem obvious to say, but, without compliance, you don’t have savings. And, non-compliance can result in your program being excluded from eligibility.
Key areas of accountability
When evaluating a TPA, there are three broad questions you can ask to begin to evaluate the performance of the relationship. The first one concerns how the TPA handles and provides access to ALL of your data. Many times, uncaptured claim data is removed from access and/or overlooked and pushed aside. However, this data contains very useful information. Uncaptured-claims data should be periodically reviewed to ensure business filters are properly being applied by the TPA and also investigated for any missed capture opportunities.
The second area to explore is the level of engagement your TPA has with your team’s 340B resources. Consider asking:
- If the TPA holds weekly recurring calls to review data
- How red flags are identified, monitored and adjusted for
- What the average response and turn-around times are for ticket submission and resolution
As you navigate the 340B program, the responses to these types of questions are extremely important in helping you optimize new opportunities and minimize potential areas of fallout.
The third consideration is TPA’s reporting capabilities. While all TPAs typically advertise a strong reporting capability, it’s important to understand the level of detail and customization they have available. It is not likely that standard, out-of-the-box reports will provide the level of information you need. So it’s essential to select a TPA with experts who can develop customized reports based on your needs in a timely manner.
The single most important attribute to ensure a successful TPA partnership is having someone on your team dedicated to monitor the full circle and the flow of data. That’s where the opportunities hide, as well as the areas of non-compliance. Finding local staff members, pharmacy technicians, purchasing agents, and pharmacy directors with visibility across the entire program who really understand the whole life cycle decline is difficult since they have other primary responsibilities. However, with a savvy 340B knowledge expert on staff, your savings and revenue are going to increase. Evaluate potential TPAs for the level of proactive data collaboration they offer so that your involvement, though minimal, can achieve the outcomes you need for a successful 340B program.
To learn more about navigating 340B programs, HealthTrust members are encouraged to email Chris at solutions@healthtrustpg.com
Chris Yoder, MHA, is the 340B MSPS Director for HealthTrust. Over the past 10 years, he has worked in various pharmacy roles at the IDN and TPA level. Most recently, as the Director of Client Services for a 340B third-party administrator, Yoder provided leadership and 340B expertise to account managers and major revenue accounts. Prior to his work in the TPA arena, he served as a Regional 340B Program Manager in Northern California for Dignity Health.
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