Lessons Learned from Top Apexus Answers 340B Interventions – Part II
by Apexus, the 340B Prime Vendor | March 4, 2019
Article 2 of 3
In this series of articles, we will highlight cases in which Apexus Answers, a resource provided by the 340B Prime Vendor Program, was a valuable resource for 340B stakeholders who contacted the call center. Read Part I of this series here.
Continuing our look into how you can utilize the Apexus Answers call center to support your program compliance, we will highlight a few more cases that show examples of interventions made through those interactions. As a reminder, you can contact Apexus Answers call center via phone, live webchat or email for all of your 340B program questions. The call center operates as part of our agreement with HRSA as the 340B Prime Vendor.
State Medicaid Agency Information
A South Carolina DSH facility had been conducting its regular self-audit and found a possible duplicate discount. Since the entity had never come across a possible duplicate discount before, it decided to call Apexus Answers to understand what its next steps should be.
Resolution: The call center started the conversation by confirming that this DSH facility was on the OPAIS Medicaid Exclusion File as carving in for Medicaid-fee for service, and that it was set up to include UD modifiers on its claims to the state per South Carolina’s billing requirements for both fee for service and managed care organization claims. However, since a UD modifier had been left off one of its claims, the call center specialist then focused on how the covered entity could gather information from the state Medicaid office. This is critical in order to validate if a rebate had been sought to determine if a duplicate discount did occur on that claim.
Outcome: The specialist looked up and provided the covered entity with the specific South Carolina state Medicaid contact. The specialist also advised that the DSH contact could call the manufacturer as well to verify no rebate had been sought, confirming no duplicate discount had occurred. If a rebate was sought, the hospital member was provided information on how to work with the manufacturer to resolve the issue. This member was very grateful for the guidance, contact information, and the next steps provided by our call center specialist. The Apexus Answers call center maintains contact information and resources to determine state billing requirements, which makes working with state Medicaid agencies easier!
340B OPAIS Technical Assistance
Another set of questions that the Apexus Answers call center receives can be categorized as 340B OPAIS (Office of Pharmacy Affairs Information System) navigation, registration and/or recertification. Each covered entity has to register its locations upon start up and then recertify them each year, and navigation of the 340B OPAIS can become complex. That’s where the Apexus Answers call center specialists come in! They have handled thousands of cases, answering such questions as “Can someone help me recertify my 340B sites?” and “How do I add a new contract pharmacy?” and “How do I verify/update my Authorizing Official contact information on the 340B OPAIS site?”
Resolution: Helping covered entities navigate the 340B OPAIS is the most common query the call center receives – and part of Apexus Answers’ core value to covered entities. Talking a covered entity through a recertification process and providing page-by-page assistance is a service the call center provides to all organizations. Call center specialists are very knowledgeable and patient during interactions and can provide resolutions and information about additional resources that the 340B Prime Vendor offers.
Caller Feedback: “I've learned more in the 20 minutes that I spent with her on the phone than I have in the three years I've been a part of the 340B program. Kudos on a great job!”
Outcome: A covered entity in Milwaukee that spoke with a specialist about how to recertify said after the call, “I've learned more in the 20 minutes that I spent with her on the phone than I have in the three years I've been a part of the 340B program. Kudos on a great job!” A Public Health Department in Kansas that needed assistance changing its Authorizing Official and recertifying on the OPAIS site wrote, “The individual who helped me was WONDERFUL! Answered all my questions, was very patient, walked me through screens, and explained what will happen next and how to finish the enrollment process. Encouraged me to call back if I have further questions. One of the best TA calls I've had anywhere!” The Apexus Answers call center takes pride in helping so many people through challenging steps in the 340B process and strives to provide the best customer service while doing it.
Medicaid Exclusion File Accuracy
A 340B manager contacted Apexus Answers with a question regarding how its retail pharmacy can carve out Medicaid and its DSH can continue carving in. The entity wanted to ensure that the state Medicaid office would know that the retail pharmacy was carving out.
Resolution: The call center specialist confirmed that the retail pharmacy and the hospital pharmacy had different NPI (National Provider Identifier) numbers, supporting different carve-in decisions. The Apexus Answers call center directed the covered entity to its specific state Medicaid billing requirement information. The specialist was able to confirm that the state being billed does in fact use the Medicaid Exclusion File as the sole source to determine which providers are carved in. The call center specialist informed the 340B manager that if the retail pharmacy did not list its NPI number in the Medicaid Exclusion File on the 340B OPAIS, then HRSA and the state Medicaid agency being billed would use the MEF to identify that NPI as a carve-out. The specialist also informed the entity that it would need to contact any state Medicaid agency being billed to determine what the state's billing requirements are and how 340B claims are identified in that state. The call center was able to provide the covered entity with the questions to ask each state agency to ensure compliance for the retail and the DSH pharmacies. The specialist also directed the covered entity to the specific HRSA webpage for additional information on this topic.
Outcome: Since the carved-in DSH entity had a separate NPI number than the retail pharmacy, and the retail pharmacy is not listing its NPI number on the MEF file, that covered entity would be compliant with purchasing non-340B drugs for its Medicaid patients at the retail pharmacy. Meanwhile, the DSH hospital can continue to purchase all other (non-retail) outpatient Medicaid medications at the 340B price since the DSH entity had listed its NPI number on the MEF file on 340B OPAIS.
Stay tuned for the next article in this series on call center interventions!