Pharmacy 340B Program Analyst

The Opportunity

Recognizing the 340B Program is highly complex and constantly evolving, those working with the Program must possess a high level of specialized training and a solid knowledge base.  Mass General Brigham (MGB) is committed to a formalized 340B enterprise-wide program serving as the institutional expert and authority over 340B Program services. 

Program goals of ensuring the greatest cost savings returns while maintaining the utmost compliance are supported by 340B Analysts. Pharmacy 340B Program Analyst II is responsible for providing ongoing program development and coordination support. responsibilities include but are not limited to 340B baseline knowledge, drug purchasing, inventory processes, monthly reporting, split-billing software maintenance, manual and robotic audits, contract pharmacy relationships, dispensing monitoring in both outpatient and inpatient settings, and all areas of program compliance.  The analyst will be required to be competent in all enterprise software as well as have thorough knowledge of all categories of covered entity status.

Key Duties

• Help manage and lead along with the MGB 340B Program Lead the 340B MGB Oversight Council and to each institutional compliance authority regarding adherence to the qualifications to the details, policies, and procedures of the 340B Program regulations and guidelines.
• Manage and maintain consistent improvement for the overall efficiency, value, and internal support of the program. 
• Develop reports and lead the analysis (cost analysis, trends, and forecasts) used to educate staff and give strategic guidance to Pharmacy and Hospital leadership.
• Responsible for routinely monitoring all areas of 340B outpatient use with Pharmacy Supply Chain and Finance to ensure maximum participation continually looking for additional qualified areas.
• Monitor utilization records and purchasing accounts to ensure the billing extract data and split billing software are working appropriately and compliantly. 
• Ensure use of 340B priced products in all qualified outpatients, implementing procedures for pricing exclusions, product shortages requiring alternative products, filtering out non-eligible transactions including, but not limited to, drugs used to treat patients during inpatient care, Medicaid patients, drugs associated with manufacturer rebates, drugs provided free by manufacturers, those provided at non-eligible locations, or written by non-eligible providers.
• Develop process of continually reviewing 340B account records for exceptions, drugs required to be purchased at WAC, quickly detecting, and addressing costly changes or over purchasing on WAC.  Monitor GPO utilizations and purchases for compliance to GPO Prohibition if required.
• Assist and monitor buyers as they replenish inventory in the mixed-use settings to see those appropriate accounts (e.g., WAC, GPO, and 340B) are used.
• Comply with all track-and-trace legal requirements of the Drug Supply Chain Security Act for purchasing and distribution of drug products.   
• Establish routine up-dating of the CDM/crosswalk for new products, product changes or errors thus ensuring the accuracy of the utilization report and split-billing process.
• Through financial analysis, strive to recognize the value opportunity of the 340B program and track the overall financial impact to the organization. 
• Collaborate with other 340B Program analysts to develop daily, monthly, quarterly and yearly audit metrics ensuring compliance with 340B program requirements and guidelines.
• Participate in constant (daily and monthly) self-audits of 340B pharmacy operations documenting procedures for presenting and resolving reconciliation issues as they arise during the monitoring and reconciliation process.
• Communicate, along with the entire 340B Program team, to all MGB staff the purpose and importance of the 340B program, establishing a clear way for them to address their problems, concerns or suggestions for improvement. 
• Develop and foster working relationships with internal working counterparts (IT, Internal Audit, Accounting and others) to facilitate productive exchanges of information to improve program efficiency and promote program compliance.
• Provide data, information and reports as needed for other business units within the organization.
• Attend conferences and meetings as requested, regularly monitor HRSA and OPA publications and websites as well as the professional media, literature, and peers to insure the 340B Pharmacy team has the latest information regarding interpretations, rulings, suggestions, and progressive ideas for improving participation. 
• Other duties as assigned

Qualifications 

• Bachelor's degree in business, accounting, finance, healthcare or related field
  
• Advanced degree is a plus
  
• 5 years of compliance, business, finance, or related experience preferred

Skills, Abilities and Core Competencies

• Excellent verbal and written communication skills
• Proficiency with Excel is required; familiarity with data query/data management, PowerPoint and Tableau preferred
• Conceptual, analytical and problem-solving skills with the ability to create forecasts and models in a complex environment are required
• High comfort level with challenge and change, meeting deadlines
• Tact, diplomacy, and ability to work with individuals at all levels of hospital and medical staff
• Flexibility of work hours when required
• Ability to work with confidential information
• Possess strong interpersonal skills to effectively communicate with cross functional teams including staff at all levels of the organization
• Ability to successfully negotiate and collaborate with others of different skill sets, backgrounds an levels within and external to the organization
• Strong problem solving skills
• Requires minimal direction from leadership and possesses the ability to learn quickly