340B Drug Pricing Program Division

The 340B Program requires pharmaceutical manufacturers to extend upfront discounts on covered outpatient medications purchased by federally registered covered entities. Congress passed the 340B Program as part of the Veterans Health Care Act in November of 1992. The program’s intent was to aid safety-net providers whom serve the nation’s most vulnerable patient populations in “stretching scarce federal resources as far as possible, reaching more eligible patients and providing more comprehensive services.” Pharmaceutical discounts extended to covered entities range anywhere from 15 to 60 percent. RWJBarnabas Health has been able to transform these savings into increased access to care and medication for eligible patients in underserved communities with the greatest need.

The RWJBarnabas Health 340B Program began with a single hospital over 10 years ago. The health system has since expanded into 6 disproportionate share hospitals and 1 hemophilia treatment center registered with the Health Resources and Services Administration (HRSA) as 340B covered entities. Each covered entity has Contracted Pharmacy agreements with a local retail network, including our own retail pharmacies. These arrangements further increase access to affordable medication for our eligible patients.

Pharmacy has a central role in the initiation, operations, compliance and auditing of this complex program. This requires a coordinated effort between the local facility and corporate pharmacy 340B team with the support of our 340B software vendor. The 340B team ensures all data is sent by our covered entities and routinely conduct data integrity reviews to maintain accuracy and compliance.

Our facilities participating in the 340B Program are subject to audit by drug manufacturers, HRSA, and Internal audit from the Corporate 340B Division. Failure to comply with 340B Program requirements could result in refund of discounts back to a manufacturer(s) or potential expulsion from the program.

In 2020 the Corporate Pharmacy 340B Team successfully conducted over 183 individual audits of RWJBarnabas Health covered entities. Additionally, the team fielded 3 manufacturer inquiries and 3 audits conducted by Cardinal Health. The Team’s efforts, executed with limited resources, helped to ensure compliant 340B Program utilization. Through continuous evaluation of 340B Program operations, the team has continued to increase efficiencies and maximize program benefits for the RWJBarnabas Health System.

340B Drug Pricing Program Divsion Leadership

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Robert Pellechio, RPh, MPA
Corporate Vice President of Integrated Pharmacy Services

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Bryan McCormick, CPhT, MBA
Corporate Director 340B Program, Corporate Pharmacy

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Angelina Bayruns, CPhT
340B Analyst, Corporate Pharmacy

Tammy Kupper, CPhT
340B Analyst, Corporate Pharmacy