Pharmacy Compliance Analyst

July 10, 2023
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Job Description

Nemours

Orlando, Florida, Nemours is seeking a Pharmacy Compliance Analyst (Full-Time), to join our Nemours Children’s Health team in Orlando, Florida. Located in Orlando, Fla. , Nemours Children’s Hospital is the newest addition to the Nemours integrated healthcare system. Our 100-bed pediatric hospital also features the area’s only 24-hour Emergency Department designed just for kids as well as outpatient pediatric clinics including several specialties previously unavailable in the region. A hospital designed by families for families, Nemours Children’s Hospital blends the healing power of nature with the latest in healthcare innovation to deliver world-class care to the children of Central Florida and beyond. In keeping with our goal of bringing Nemours care into the communities we serve, we also provide specialty outpatient care in several clinics located throughout the region. The Pharmacy Compliance/Business Analyst manages the 340B program at Nemours Children’s Hospital, Orlando and assists with the maintaining of pharmacy financial, productivity and operational performance analytics. This position is responsible for 340B compliance, program integrity and financial optimization of the program. The analyst will be responsible for program management and coordination, configuration and maintenance of software systems, providing support for the daily operations of the covered entity to maintain compliant 340B practices, and other projects as assigned by the Pharmacy Business Manager. The analyst will complete, validate and document completed internal self-audits and external audits related to program compliance.

The analyst is also responsible for ensuring continuous alignment between the covered entity operations and all 340B policies and procedures. The analyst is responsible for associate education necessary for the 340B program, and the oversight of inventory practices related to the 340B program. In order to accomplish these roles, the analyst must establish and maintain excellent customer service relations with individuals, committees and all associated stakeholders in the 340B program. 340B Program Coordination: (10%) Serves as primary internal and external program coordinator for all 340B related matters and maintains the 340B program’s standards. Ensures HRSA requirements for program qualifications are met. Serves as the institutional compliance expert on 340B regarding program details, policies, and procedures of the virtual inventory processes and required for mixed-use areas. Serves as the first step in scoping and escalating discovered operational or compliance issues. Escalates any identified compliance issues to Pharmacy Business Manager and entity stakeholders. Provides oversight and leadership from the department of pharmacy for the 340B program. Will help lead and assist the organization’ s 340B Steering Committee.

Actively engages with senior leadership and participates in decision-making processes related to the implementation of new 340B processes. 340B Program Policy and Procedure Development: (5%) Ensures that policies and procedures are developed and implemented according to organizational, federal, state and federal requirements and guidelines. Assists in maintaining a regular compliance audit program to identify risk and prevent duplicate discounts and diversion. Develop systems and processes to limit program liabilities. Develops and modifies 340B policies in accordance with state, federal, and hospital program requirements. 340B Program Education: (5%) Provides ongoing training, education, and communication required for the 340B program. Develops training and competency materials for all staff and leaders who work with the 340B program. Regularly communicates with all staff involved with the 340B program to be sure that processes remain efficient and to address any problems or suggestions for improvement. Establishes a clear way for staff to communicate concerns to the analyst. Expand professional development through related classes and seminars, current publications and regional/national association membership participation.

340B Program Guidance Surveillance: (5%) Monitors and assesses 340B guidance and or rule changes. Attends regular 340B training and shares learnings and hot topics with staff. Routinely monitors industry publications and websites as well as professional media, literature, and peers to ensure that the institution has the latest information regarding interpretations, rulings, suggestions, and advanced ideas for improving participation. Ensures that the 340B pharmacy program is continuously compliant with 340B federal regulations. Provides expertise on all 340B program legislation and policy changes from HRSA and OPA, informing and collaborating with legal and compliance teams. Develops knowledge and maintains awareness of current regulations, trends, and issues pertaining to the 340B program. Works with affiliated departments (finance, information technology, medical staffing office, etc) to ensure 340B program integrity. 340B Program Self-Audits: (40%) Develops, executes, and documents self-audits of the 340B process. Coordinates and ensures follow-up of findings. Reviews and monitors all points of service where 340B participation occurs to ensure policy and procedure compliance, covered entity eligibility, and patient eligibility.

Monitors utilization records and 340B purchasing accounts to ensure that software or tools are working properly and accurately, performing audits or compliance assessments internally as needed, and coordinates external compliance assessments with outside firms to validate internal processes. Responsible for the day-to-day management, compliance review, and operations of clinic-administered medications in eligible locations, mixed-uses areas managed by split-billing software, and outpatient prescriptions filled by a contract 340B pharmacy. Conducts monthly audits of all 340B eligible locations to verify adherence with the 340B program guidelines and policies. 340B Program External Audits: (5%) Provides oversight for all audits performed by independent external auditors. Participates and is involved in any and all 340B program audits. Coordinates external compliance assessments with outside firms, where appropriate, to validate internal processes. 340B Program Program Enhancement/Optimization: (10%) Assesses opportunities for cost savings and business improvement in 340B contract pharmacy utilization. Analyzes utilization of the program and existing software to identify ways to compliantly use the 340B program to its fullest extent to meet the needs to underserved patients. Monitors all outpatient points of service to continually check for new areas that may qualify for the 340B program. Works to continuously improve the 340B program performance through program surveillance and identification of program optimization.

Creates/maintains monthly reports of 340B program metrics and financial savings. Analyzes monthly reports, completes monthly variance reporting, and identifies cost savings and system improvements to maximize compliance. Develops action plans to mitigate and/or remove any potential or identified compliance concerns and works to implement approved programmatic changes. Develops internal and external customer service relationships for effective program management. 340B Program Purchasing/Inventory Oversight: (10%) Ensures compliance with regulations related to 340B purchasing and provides real time guidance to Pharmacy Business Manager, buyers and staff on purchasing, inventory management and other practices which maximize 340B compliance and savings. Provide each buyer with information needed to place orders using the appropriate accounts (e. g. WAC, GPO, 340B and non-340B) to replenish inventory in the mixed use inventory setting. Routinely monitors utilization records and 340B purchasing accounts to ensure that software or tools are working properly. Serves as split billing software expert in order to troubleshoot and continually improve software functionality.

Ensures integrity of split billing software and reviews applicable software reports to identify areas for improvement. Oversees 340B regulatory aspects of the inventory purchasing process for outpatient, inpatient, and mixed-use areas. Data Analysis (10%) Perform data pulls and create dashboards to help track operational efficiencies. Develop analyses that help the organization understand and monitor performance, break down key performance indicators and identify new opportunities. Create ongoing reports and high-impact dashboards and visuals that effectively communicate performance to operational and clinical leaders and stakeholders. Track and analyze trends to make appropriate recommendations that will positively impact workflow and efficiencies. Job Requirements Bachelor’s Degree required. A c ombination of post-secondary education and experience may be considered in lieu of degree. Minimum of five (5) + years experience required. Previous experience with business, managing data, performing data analytics required in healthcare related field.

Ability to meet assigned project deadlines and adhere to reporting procedures and requirements. Experience in hospital or retail pharmacy is helpful but not required. Previous 340B analytic experience (auditing) highly desired, but not mandatory. 340B University Certificate, 340B Advanced Operations Certificate preferred.

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