You and Your 340B Program: Are You Compliant or Confused?

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  by Venson Wallin and Bill Bithoney, MD, The BDO Center for Healthcare Excellence and Innovation What is the 340B program? The 340B program is a means through which providers, known as “covered entities,” can offer pharmaceuticals to a greater amount of eligible patients than they could at traditional manufacturer pricing. This is because the program requires that manufacturers sell the drugs to the eligible providers at a discount, thereby enabling a larger number of those in need to get the assistance they need with purchasing their prescriptions. The 340B program is very popular for this very reason; covered entities are able to purchase drug supplies at the 340B discounted price, and then bill the patient’s insurance company the traditional rate. This “margin” generates much needed profit for some of the more income-challenged providers, while having minimal impact on the Medicare and Medicaid program costs. The patient wins, the provider wins, and the government programs win. Providers understand the upside, and annual 340B drug spending by covered entities exceeds six billion dollars and approximately one-third of U.S. hospitals participate in the program. The spending and number of participating providers is forecast to increase significantly during the coming years. In 1992, Congress created the 340B program via Public Law 102-585, the Veterans Health Care Act of 1992, which is otherwise known as Section 340B of the Public Health Service Act. The law requires drug manufacturers that participate in the Medicaid program to agree to provide discounts on covered outpatient drugs purchased…

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President’s Message

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Dear HFMA South Texas Chapter Membership, Happy New Year! Here is to a happy, healthy and prosperous 2015! I hope everyone had a blessed and relaxing Thanksgiving and Christmas season. Two of my top resolutions include strengthening and growing my faith. I will be leading a Men’s group through a daily reading and journaling process in the Bible. The other is committing to a consistent cardio and strength training program. With all of life’s business and distractions, I wish everyone the best in achieving your goals. How about that Super Bowl on Sunday? What an ending to the game! As a diehard and loyal Chicago Bears fan I must say that I enjoyed the commercials more than the game itself. It’s times like now I wished I lived in Texas as we have negative degree temps with over 8 inches of snow here in Omaha, Nebraska. What am I thinking? I have always said that I appreciate and enjoy the Midwest’s four seasons, but would rather be staying at one on the beach right about now. We have come off a very successful quarter with great attendance at the Region 9 Conference in New Orleans, our December and January webinars, and most recently, the Healthcare Landscape Conference in San Antonio. All agendas were packed with timely, quality education combined with excellent networking opportunities. Last Saturday, our officers, board members and committee chairs attended a one day Strategic Planning Meeting in San Antonio. The main objective was to create and execute…

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4 Steps to Managing Supply Chain in Labor and Delivery

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by: Karen Wagner Being responsive to the supply needs of a demanding department requires determining who can manage supplies most efficiently and what tools and storage methods can offer the greatest benefits. Here, Texas Children’s Hospital shares four strategies for success. Effectively managing a supply chain is an enormous undertaking for any healthcare organization, but add in the unpredictability of a labor and delivery environment and the challenges multiply. A case in point is the Pavilion for Women at Texas Children’s Hospital, Houston. The 100-bed facility, opened last March, specializes in multiple births and high-risk pregnancies and can accommodate 5,000 births annually. Evidence of the unpredictable environment came one morning last April: One minute, the hospital was quiet; the next, a patient was brought in who gave birth prematurely to sextuplets. According to Rick McFee, Texas Children’s Hospital’s director of supply chain management, being ready for the unexpected is the focus of his department, which also manages supplies for the 555-bed pediatrics hospital and a 24-bed pediatric acute care facility on Houston’s west side. “It’s very difficult to have any kind of consistent supply utilization. You may have three days where you have very low volume activity, and then you may have four days in which you’re really struggling with capacity,” McFee says. “You may have days where supplies are barely used at all; then, you’ll have days where they’ve used everything we’ve got. So we’ve got to be very nimble. We’ve got to be able to respond very quickly.”…

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Choosing the Right Benchmark

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The U.S. stock market rally over the last five-and-a-half years has led to impressive returns across nonprofit investment portfolios. While it is easy to become complacent in a period of outsized returns, fiduciaries must ask themselves two critical questions: • What is the source of these high returns and are they sustainable? • Is recent performance the result of superior asset allocation and manager selection, or simply a rising tide lifting all boats? Importance of Benchmarking Fiduciaries are concerned with growing the assets of their foundation or endowment. Over the last five-and-a-half years, many organizations have seen that goal realized, as the U.S. stock market, international stock markets, global bond markets and real estate have all offered impressive returns. In fact, many organizations have been able to fulfill their spending requirements and still realize substantial appreciation of their portfolio. While it is easy to get comfortable when portfolios continue to grow, fiduciaries should work to ensure that their organization is maximizing opportunities. But how can a nonprofit determine if they are truly maximizing the opportunities in the markets? The answer comes from portfolio performance attribution through relevant benchmarking. Establishing a benchmark is critical for many reasons, the most important of which is understanding the source of performance. For example, an investment portfolio may earn a return of 10% in a given year. A 10% return allows the organization to meet all budgeted spending requirements, keep pace with inflation, and experience real growth. However, over the same period a collection of…

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Open Access: Integrating Urgent Care and Primary Care

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By Christopher Franklin Primary care and urgent care have never been the closest of allies. Concerns about disruptions to care continuity and coordination – not to mention competition – have historically led primary care providers to be tentative about the role of urgent care centers (UCCs) in the care continuum. Yet building a strategic alliance between the two is becoming a necessity as our health needs overwhelm our primary care resources. While population health expectations shift, insurance coverage expands, care delivery models evolve, and the number of available PCPs dwindles, access to primary care services becomes increasingly constrained. At the same time, access to urgent care is ramping up. Since 2008, the number of UCCs has grown from 8,000 to about 9,300 sites across the nation. The expansion of urgent care is more indicative of the growing demand for acute care services than a competitive threat to primary care. Health systems can help ease the burden on PCPs, enhance access to care (particularly non-emergent acute care), and better meet patient demands by integrating UCCs into their primary care networks. The Growth of America’s Aging Population The growth of the country’s aging population is one of the factors restricting the availability of appointments with PCPs. Estimates suggest that 81% of the change in demand for health services from 2010 to 2020 will be the result of aging and population growth. And the over-65 patient population isn’t just growing – they’re also living longer and with an increased prevalence of comorbidities that…

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President’s Message

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Happy Fall and Happy Halloween, South Texas Chapter! This time of year is one of the Snyder household’s favorite! College football is full effect, leaves are changing colors, warm apple cider is in the crockpot, pumpkin carving is taking place, pumpkin seeds are in the oven and of course we are taking our 17 month old (who is an owl this year) out to trick-or-treat so that mom and dad have plenty of candy for the winter ahead. As we look back on the last three months, South Texas continues to thrive! We set a record attendance at our August Summer Institute in Austin with over 100 attendees! The day was filled with education around top healthcare finance trending topics as well as plenty of networking opportunities. Our September Women’s Forum in Edinburg and October Fall Institute in San Antonio continues to be a success along with our monthly free educational webinars. Membership is sitting at 325 members strong as we climb back to our goal of 399. Please make sure to renew your HFMA memberships at www.hfma.org/membership. As always, our chapter would like to recognize and warmly thank our sponsors that help generously support all of our programs and other various initiatives. If you haven’t already, please check out the certification investments of greater than $1,800 we have made in you regarding the CHFP and now the CRCR. By now you should have received our Membership Satisfaction Survey which was emailed out to you around October 21st. Please take…

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The Financial Aftermath of a Merger: Identifying Debt Synergies

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By: Ken Gould & Brian Cafarella, Lancaster Pollard Facing increasing financial pressures and a difficult operating environment, more and more rural and community hospitals are seeking to merge or affiliate to gain operating efficiencies. The recent acceleration of consolidations has in part been fueled by the Affordable Care Act (ACA), which has applied downward pressure on reimbursement rates while costs for regulatory compliance and infrastructure continue to increase. A recent report by Kaufman Hall noted that in 2013 there were 98 affiliations/mergers, a 3% increase from 2012 and a 51% increase over 2010. As such, hospital CFOs are keeping very busy evaluating potential merger opportunities. Given the amount of time and due diligence invested in considering potential combinations, one post-merger synergy that must be considered is improving the debt structure of the newly-combined system. Such debt synergies can be defined as cash saving opportunities derived from refinancing, consolidating or restructuring debt post-merger. How to Determine if a Debt Synergy Exists Understanding the financial profile and debt structure of the combined system post-merger should be the first step to determine if debt synergies are available. This is easier said than done. Nonprofit hospitals and health systems have historically been financed with many varieties of debt and structures: fixed or variable interest rates, a range of terms and amortizations, sinking funds or escrows, taxable or tax-exempt structures, derivatives, capital leases and obligated groups among other structures. Since the devil is in the details, a thorough review and understanding of the existing debt…

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Appropriate Level of Care and the 2-Midnight Rule, Where It Stands as of NOW…

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By Edward J. Niewiadomski, MD and Laureen A. Rimmer, RHIA, CPHQ, CHC, BESLER Consulting Effective October 1, 2013, The Centers for Medicare and Medicaid Services (CMS) implemented a new rule, the “2-Midnight Rule” that is intended to clarify which patients are sick enough to be admitted to a hospital by adding “midnight” as a point in time for determining inpatient length of stay and requiring physicians to certify that they have the expectation of care surpassing two midnights. Medicare would then pay inpatient hospital rates. Prior to this rule, CMS outlined observation care as short term and generally would not exceed 24 hours but could be up to 48 hours in rare and exceptional cases. It is important to note that a New Jersey State regulation stipulates a length of stay criteria of less than 24 hours for observation services. The New Jersey Department of Health and Senior Services, N.J.A.C., Title 8, Chapter 43G-32.21 outlines the state standards for observation services and scope which is more stringent than the CMS guidance on observation services. The key elements of the 2-Midnight rule require documentation in the medical record for medical necessity and a presumption of the length of stay. The focus of the documentation requirements for Medicare inpatient admission is as follows: Inpatient admission order at the time of admission by a physician or qualified practitioner licensed by state to admit inpatients and who has admitting privileges; Physician certification of medical necessity includes (before discharge): Inpatient admission order signed/authenticated by the…

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