In an era driven by data and technological advancements and in an industry marred by uncertainty, 340B program leaders are poised to embrace a groundbreaking opportunity. Imagine a world where the complexities of 340B program management are effortlessly deciphered, and strategic decisions are guided by powerful insights derived from cutting-edge artificial intelligence. The time has come for 340B leaders to unleash the true potential of their program through the seamless integration of AI and the groundbreaking capabilities of ChatGPT. Prepare to embark on a transformative journey where the convergence of human expertise and machine intelligence drives unparalleled efficiency, compliance, and patient value.
Advancements in technology have revolutionized the way organizational leaders across all industries make strategic-decisions. The most impactful technological advancement to organizational management arguably lies in the enhanced ability to aggregate, evaluate, and understand big data. In fact, the ability to interpret big data is in such high organizational demand that dozens of software platforms have emerged in just the past handful of years capable of performing increased exploratory data analysis (EDA).
Enhanced EDA functions are prevalent in many of the software technologies you may currently be utilizing in your health centers such as Microsoft Power BI, IBM Watson, Oracle Healthcare Analytics, and SAP Analytics Cloud. These software platforms (among others) offer increased analytical scripting capabilities, some of which are built-in to their toolkits and very user-friendly. The ability to perform a wide range of data transformations, computations, and analysis on your data allows you to customize and enhance your data preparation and analysis workflows to your specific needs.
So what does this mean for 340B leaders?
For more than two decades, 340B leaders have been tasked with managing the traditional 340B compliance elements outlined by the Health Resources and Services Administration (HRSA) such as preventing diversion and duplicate discounts, accurately registering on the Office of Pharmacy Affairs Information System (OPAIS), etc. Many organizations successfully employ a repeatable process of auditing 340B captured claims, correcting instances of non-compliance, and reporting 340B savings figures to senior leadership. Various iterations of these repeatable processes have commonly been considered best practice approaches to 340B program management and oversight. In just the past 3 years, all that has changed.
Today, 340B stakeholders across the country are anxiously waiting to find out how the day’s news will impact their administration of the 340B program. With individual pharmaceutical companies imposing unique restrictions to 340B pricing for certain covered entities combined with the lack of definitive and enforceable 340B regulations on behalf of the federal government, 340B leaders are overwhelmed with uncertainty and stuck in reactionary-mode. The classic cookie-cutter model for 340B program monitoring and oversight is no longer sufficient to effectively manage risk but, the power of AI and ChatGPT can help fill the gaps.
Let’s start by considering the emerging financial risks to 340B organizations as a result of the various pharmaceutical manufacturer restrictions to 340B pricing at contract pharmacies. Based on a number of recent manufacturer’s 340B policies and/or policy revisions, some 340B leaders are forced to designate a single contract pharmacy to continue receiving a particular manufacturer’s drugs at the 340B price for the next 12-month period. These particular policy notifications are often delivered approximately 1 month before they take effect. Meaning, 340B leaders have roughly 30 days to measure the financial loss of the manufacturer’s policy across their 340B contract pharmacy universe, identify the optimal single pharmacy to designate, communicate their analysis to senior leadership, make the single-pharmacy election on a third-party platform and subsequently communicate the election to their applicable wholesaler…. yikes! At a time when preserving the maximum amount of 340B savings is the most critical decision at-hand, employing inefficient processes will consume valuable time, resources, and effort, ultimately increasing the risk of a suboptimal contract pharmacy designation.
Facing the reoccurring decision for which contract pharmacy to designate for access to a particular manufacturer’s 340B priced drugs when a new restrictive policy is announced, many 340B leaders will take the approach of assessing each individual contract pharmacy’s historical financial performance of the applicable medications, in terms of total 340B savings realized. Covered entities with vast contract pharmacy networks often default to comparing whole-period totals calculated across multiple spreadsheets/workbooks for each contract pharmacy or chain of pharmacies, then select the pharmacy with the best historical performance to designate. Honestly, it’s a fair and logical approach. However, several factors affecting each pharmacy’s 340B viability for the upcoming year such as the number of refills remaining on each eligible prescription, trends in the pharmacy locations used by your patient base, and recent payer reimbursement changes for the applicable drugs were likely omitted from the analysis and subsequently not considered when the designation was made.
What if the same input data used to calculate each contract pharmacy’s historical 340B financial performance for the applicable manufacturer’s drugs could instead be used to instantaneously predict each pharmacy’s future 340B savings estimations? Well, the technology not only exists, now is the perfect time for 340B leaders to seize the opportunity to leverage it.
How to use it:
On the analytical software platform of your choosing, consider taking each contract pharmacy’s historical 340B utilization input data and performing exploratory data analysis (EDA) to investigate and summarize the main characteristics, patterns, and insights of the data. Relevant data attributes for consideration include but are not limited to:
Month-over-month comparisons of Rx volume and 340B savings generated for the applicable manufacturer’s drugs, by pharmacy
Reimbursement amounts for the applicable drugs, by payer
The number of 340B-eligible remaining fills on each applicable prescription
The probability of a new prescription being written upon the exhaustion of remaining fills
By performing EDA on the historical 340B financial performance input data, 340B data analysts can identify patterns, correlations, and trends across the entire dataset that may not have been readily apparent. How many months reviewing summary reports from your third-party administrators would pass before you noticed a material increase/decrease in patient volume at one contract pharmacy vs. another, especially at the manufacturer-level? Appropriate EDA practices help recognize these types of trends and in addition to bringing them to your attention, can provide insight as to just how impactful they are to your objective.
With an enhanced understanding of the patterns, correlations, and trends across your entire 340B contract pharmacy universe for the applicable manufacturer’s drugs, 340B data analysts can now apply the most relevant trends and patterns to their historical 340B utilization data. These insights take the form of rule sets within your analytical model. Rule sets serve as guidelines for designing database structures, defining relationships, and validating data.
It’s important to note that choosing the best rule sets for your analytic model may require a significant time commitment early-on to fine-tune but, once established will revolutionize the way you make strategic decisions for your 340B program.
Oh, did I mention that once you design a model you’re confident/comfortable with, you can instantaneously run the same analysis for any manufacturer’s affected drugs as frequently as you want and/or need!
The ability to include current factors in your estimation of future performance using data-driven results is the best method to determine which contract pharmacy is truly the most advantageous to designate for the coming year.
Where you can start:
Understanding that the technology exists to perform complex data analytics and modeling is great but not every 340B leader is a data wizard! Fear not, help may be closer than you think.
First and foremost, many mid to large-size health systems employ robust information/healthcare analytics teams with personnel capable of designing and/or performing the types of EDA and analytic modeling previously noted.
Another internal consideration is if your organization has an Internal Audit department. A growing number of the software platforms utilized by internal audit teams include add-ons capable of performing advanced data analytics and scripting. As a result, many organizations have added internal auditors with advanced data analytics capabilities to their teams.
For the same reasons not every 340B leader is a data wizard, every data analyst isn’t educated on the intricacies of the 340B program. Regardless of what resource is available to you, responsibility for interpreting the results of the EDA and selecting what factors to apply to the rule set falls on 340B leaders.
So how can 340B leaders communicate data analytics requests to internal/external teams effectively? Look no further than ChatGPT.
The Power of ChatGPT:
ChatGPT is a language model developed by OpenAI designed to generate human-like text responses given a prompt or a conversation context. ChatGPT can understand and generate natural language responses, allowing it to engage in interactive conversations with users. This groundbreaking technology can be a valuable tool for 340B leaders to communicate data analytics requests to internal/external analytics teams. Here are a few ways ChatGPT can help facilitate this process:
Natural Language Understanding: ChatGPT is designed to understand and process natural language. 340B leaders can communicate their data analytics requests to ChatGPT using plain, conversational language, without the need for complex technical jargon or formal query languages. This makes it easier for 340B leaders to articulate their requirements without having to be well-versed in technical aspects of data analytics.
Clarifying and Refining Requests: 340B leaders can engage in a back-and-forth conversation with ChatGPT to refine and clarify their data analytics requests. ChatGPT can ask follow-up questions to seek additional details, suggest potential approaches or metrics to consider, and help 340B leaders articulate their needs more precisely.
Understanding Feasibility and Limitations: Managers can consult with ChatGPT to understand the feasibility of specific data analytics requests and any limitations that might exist. ChatGPT can provide information about data availability, required resources, potential challenges, and alternative approaches to consider.
It's important to note that while ChatGPT can assist in communicating data analytics requests, it should be used as a supportive tool rather than a replacement for direct communication with the analytics team.
Leveraging ChatGPT to manage 340B operational risks:
Burnout and stress are commonly considered to have the most profound impact on the turnover rate among leaders in the healthcare industry. The immense pressure on 340B leaders in the current environment to ensure the efficient use of discounted drugs, meet strict policy requirements, and balance financial considerations is no exception. Considering the dynamic and ever-changing current 340B landscape, covered entities must remain agile and new hires (especially external hires) must achieve a comprehensive understanding of their entire 340B universe in short-time.
While comprehensive and proven 340B education and training programs have been available to 340B stakeholders for years, they simply do not fully-encompass today’s entire 340B environment. Today’s 340B leaders are faced with complex and unconventional problems that do not have clear-cut solutions and must consider thinking outside-of-the-box. ChatGPT can be a tremendous resource.
For example, a newly hired 340B leader that despite being well-versed in the 340B program is likely less understanding of their new organization’s structure and the roles ancillary departments may play in the administration of their 340B program. Given the current 340B environment, the new 340B leader will probably be presented with problems that require immediate action before they have a comfortable understanding of their new organization.
ChatGPT’s ability to present 340B leaders with out-of-the-box responses unlocks a new method for brainstorming and provides additional considerations less commonly shared among the 340B community. Furthermore, the technology can be leveraged to instantly draft messages for communication.
Let’s say the newly hired 340B leader is assessing a current 340B issue that has implications on the organization’s finance department. Let’s also assume the 340B leader finds that there has historically been minimal collaboration between the organization’s 340B and finance teams. The 340B leader determines the best course of action to be the establishment of a cross-functional team with the finance department and opts to send an email request to the organizations finance manager.
Email correspondence can often consume a significant amount of time in professional settings resulting in inefficiencies and wasted time. By simply asking ChatGPT, “what is an example email to invite a finance manager to join a cross functional 340B oversight team” a comprehensive email is generated in seconds from the software to include:
An inviting opening paragraph describing the objective of the email
A brief paragraph describing the purpose of the cross-functional team
The goals and responsibilities of the team
What the finance manager will gain from participating in the team
A brief paragraph expressing professional curtesy for their time
A concluding paragraph with a concise and specific call to action from the finance manager
By no means should the 340B leader simply cut and paste the message in-full but, spending a few minutes altering a few of the details is much more efficient than starting from scratch!
Risks of using AI and ChatGPT technologies:
On behalf of an audit and consulting firm dedicated to helping 340B covered entities maintain program compliance and manage risk, it would behoove me to overlook the risks associated with using these technologies.
First and foremost, 340B leaders should be sure to inquire if their organization has a policy specifically prohibiting the use of ChatGPT or other AI technologies.
If permitted to use, users should maintain the highest privacy standards with regards to not-sharing any personal emails and/or Protected Health Information (PHI) with the software. It’s important to remember that the information entered into these platforms is potentially exposed to external vendors and third-party companies.
Lastly, it's important to note that while ChatGPT is a powerful tool, it has limitations. It may occasionally produce incorrect or nonsensical responses, and it can be sensitive to the phrasing and wording of prompts. Additionally, as a language model, it does not possess true understanding or reasoning capabilities and may generate responses that seem plausible but are not factually accurate. Care should be taken when relying on its responses, and critical information should be verified from reliable sources.
Conclusion:
In the realm of 340B leadership, the power of AI and ChatGPT holds the promise of unprecedented success. By leveraging these cutting-edge technologies, leaders can enhance their decision-making, streamline processes, and unlock new insights to optimize the program's impact. The ability to harness AI and ChatGPT enables leaders to sift through vast amounts of data, uncover patterns, and make data-driven decisions with greater precision and speed. Moreover, these technologies provide an avenue for improved communication, allowing leaders to engage with stakeholders more effectively and address their concerns promptly. By embracing the transformative potential of AI and ChatGPT, 340B leaders can navigate the complexities of the program with confidence, drive innovation, and ultimately, create a more efficient and equitable healthcare landscape for the benefit of all.
Reach out today to see how Virtue Audit and Consulting Group can help you revolutionize the way you manage your 340B program.