Epic and 340B Relationship Status: It’s Complicated.
My role at The Alinea Group is as a subject matter expert in Epic Willow and Epic 340B reporting. I get to see current implementations as well as help with new ones. My role in another life is as an Epic Willow consultant, performing all possible Willow build, inpatient, inventory, ambulatory, order sets. If it’s even remotely pharmacy related, I’ve done it. I have been lucky enough to see and actually build in 15 different Epic instances. I have helped work with over 20 Epic customers with Alinea and processed data from many more.
The one common factor among ALL of those Epic builds is…they are different. Each Epic customer, if they are lucky enough to start with the foundation system (and I have worked with many that started before foundation was a thing), have managed to still build a unique system. Why? There are many reasons, but my working theory is that sites tend to build their old EMR in Epic. Whatever the reason, no two Epic instances are ever the same.
What does that have to do with 340B and Willow? Well, everything. When building the infrastructure around 340B and Epic, there are many questions that need to be pondered and answered. Mind you, these aren’t all necessarily Epic-specific, but Epic is what I know. If I start spouting Meditech or Cerner knowledge, run away.
Check out these questions below that you should consider in the Epic and 340B relationship.
- Who is your 340B TPA? Each Split-billing Software TPA has nuances and different capabilities in regard to EMR data feeds and integrations.
- What Willow modules are active? Willow Inpatient, hopefully. Willow Ambulatory? Willow Inventory? OpTime? Anesthesia?
- How do you handle the modifiers? Willow build? Claims build? Both?
- Are your Willow implied units consistent/up to date?
- Do you use FAM orders? CAM orders?
Reporting & Billing Questions
- Did you write your own Epic report? (Nothing wrong with that, but there are many lessons learned from homegrown reports, both good and bad).
- For your reports, do you do any post report processing, or is it automated?
- Do you bill using HB? PB? Both?
- Do you keep your med lists up to date? Including ADS cabinets? Do you use any third party programs for this? Do you sync your med lists to your central pharmacy?
- How do you handle payor changes? Do you retrigger charges in Willow for payor or class change? What about secondary or tertiary payors and changes?
- How do you handle patient class changes? Do you keep the original patient class, or retain the final patient class?
- Is this just inpatient, or are meds administered in clinics?
- Are you Medicaid Carve In or Carve out?
- Does your state require modifiers for Medicaid? Medicaid Managed Care?
- Do you maintain eligible Epic departments anywhere?
- Are you charged on dispense? Charge on Admin?
- If you are charged on admin, do you charge for the scanned components? What’s your scanning compliance?
- Do you use dispense prep? What’s your scanning compliance there?
- Do you use CNR for compounds? Do you link your CNRs to the dispense/administration so that you can charge for and accumulate the components?
- Do you document or charge for waste? Do you accumulate waste?
- Do you need to worry about the Orphan Drug Exclusion?
- Do you exclude any other drugs? ERX or NDC level or both?
The Devil is in the Detail
As you can see from this example list of questions, it’s important to think through all of these questions and downstream impact with an expert. You need to be aware of what decisions have been made – by both finance, operations, or regulatory – and how those affect your program. What seem like minor details can make all the difference in maximizing 340B savings and mitigating unnecessary compliance risk.
Remember, with great savings, comes great responsibility. Or is that power?
*Author Scott Patton is an expert in EMR with over 25 years as an Information Systems Pharmacist. For more information on Scott’s background, please visit Alinea’s team page. If you would like to inquire further with Scott on Epic, 340B, or other pharmacy-related matters, he can be reached via email at email@example.com.