Compliance is a cornerstone of any successful 340B program with prescriber list maintenance being a key element. Failure to maintain an entity’s prescriber list may create diversion. Conversely, if new prescribers are not added to the list, an entity could miss out on the 340B benefit associated with that prescriber. The five steps outlined within this article will help keep your prescriber list accurate and up to date, ensuring no ineligible scripts will be accepted, and reducing the risk of diversion:
5 Steps to Prescriber List Maintenance:
1) Review your prescriber list regularly to ensure each prescriber is listed appropriately
2) Communicate changes internally when a prescriber has resigned or retired so they can be terminated from the prescriber list; this step will ensure prescriptions written after their departure date are no longer accepted into your program
3) Ensure the prescriber list includes providers’ start and end date, employment status, and entity locations to make sure they are working in locations registered on the OPA database
4) Notify any third-party administrator(s) of any prescriber list terminations or additions so that they can apply the appropriate filters to your data
5) Have measures in place to review prescriptions that could potentially be deemed ineligible due to prescriber changes – internal auditing is key to ensure prescriber changes have taken effect with any 340B processors
Prevention is essential for successful prescriber list maintenance. Excluding ineligible prescribers is the proactive approach to avoiding diversion, program clean up, and inventory issues that may later need to be reported to drug manufacturers.
Have more questions about compliance? Let ATRIA 340B be your guide!
This post is part of our staff contributor series and was written by Miranda Luman, Finance and Quality Analyst