Purchasing & Inventory Management Flashcards

Which of the following best characterizes a 'ship-to/bill-to' purchasing arrangement in a 340B context?

Answer: A manufacturer ships a drug to a contract pharmacy but bills the covered entity at the 340B price

In a ship-to/bill-to arrangement, the manufacturer ships directly to the contract pharmacy (ship-to) but invoices the covered entity (bill-to) at the 340B ceiling price.

A 340B covered entity's internal audit reveals a 2% diversion rate in its contract pharmacy network. Under HRSA guidelines, the entity should:

Answer: Self-report the findings, implement corrective action, and repay manufacturers for diverted drugs

HRSA expects covered entities to self-report diversion findings, take corrective action, and repay manufacturers for any overcharges resulting from non-compliant transactions.

What is the purpose of HRSA's Apexus Prime Vendor Program (PVP) in relation to 340B purchasing?

Answer: To negotiate additional sub-ceiling pricing and provide purchasing support to 340B entities

The Apexus Prime Vendor Program negotiates pricing below the 340B ceiling (sub-ceiling prices) and provides tools and support to help covered entities optimize their purchasing.

A 340B covered entity uses a third-party administrator (TPA) to manage its contract pharmacy claims. Who bears legal responsibility if the TPA submits non-compliant 340B claims?

Answer: The covered entity retains primary compliance responsibility

Regardless of the use of TPAs, the covered entity is ultimately responsible for the compliance of all 340B transactions conducted on its behalf.

Under the 340B statute, which patient criterion is NOT required for a patient to be considered eligible for a 340B-priced drug?

Answer: The patient must be uninsured or enrolled in Medicaid

Insurance status is not a criterion for 340B patient eligibility — insured patients (including those with commercial insurance or Medicare) can qualify as long as other eligibility requirements are met.

When performing a 340B inventory audit, which metric is most useful for identifying potential duplicate discounts in a fee-for-service Medicaid population?

Answer: 340B drug claims cross-referenced against Medicaid rebate invoices for the same NDC and date of service

Cross-referencing 340B claims against Medicaid rebate requests by NDC and date of service directly identifies transactions where both a 340B discount and a Medicaid rebate may have been obtained.

A covered entity's 340B coordinator discovers that a recently closed outpatient clinic is still listed as an active child site in OPAIS. The most compliant immediate action is:

Answer: Immediately terminate the child site in OPAIS and cease 340B purchasing for that location

Covered entities must promptly remove closed sites from OPAIS; continuing to purchase 340B drugs through a non-operational site registration is non-compliant.