The Design and Implementation of a 340B Program Effectiveness Dashboard

Date

2014-05

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Abstract

Background: The 340B Drug Discount Program is a federal program enacted by Congress in 1992 that requires participating drug manufacturers to provide discounted prices on covered outpatient drugs to eligible covered entities that serve the country’s indigent and vulnerable patient populations. Although not novel to our health care system, today’s political environment has led to a surge of visibility in the 340B program as it faces Congressional scrutiny that pressures for growth containment, increased program oversight and enforcement by the government and consistency in regulatory compliance. In response to this vigorous regulatory landscape, covered entities are more than ever held accountable for the manner in which they utilize the program. Historically, the 340B program has lacked a metrics-driven reporting framework that captures value of the 340B program to the covered entity, the benefits to the underserved populations from the covered entity with its realized savings, and cost consequences associated with statutory compliance.

Objective: The objective of this project is to design and implement a metrics dashboard that supports a macro-evaluation of 340B program effectiveness and integrity for covered entities within a Disproportionate Share Hospital (DSH) eligible health system.

Methods: In order to ensure a comprehensive measurement of program effectiveness, a stakeholder needs analysis was completed. The results of this stakeholder analysis were compartmentalized into four domains; cost savings, program maintenance costs, community benefit and compliance. The metrics within each domain would be established based on relevancy, utility, and data availability. Data collection methodology was defined through the creation of a data collection tool, which was validated through a facility application pilot prior to system-wide implementation.

Results/Expected Uses: This project resulted in the design and implementation of a dashboard which includes relevant metrics within four domains; cost savings/revenue, program maintenance costs, community benefit and compliance. Primary metrics of each domain are designated through a user interface dashboard gage. The dashboard allows for graphical representation of all other metrics featured in each domain to support quarterly as well as annual trending and evaluation. The dashboard was implemented for all Memorial Hermann Health System 340B facilities and meets the aims of internal benchmarking and macro-evaluation of 340B program effectiveness.

Conclusions: The design and implementation of a 340B effectiveness dashboard at a health-system demonstrated that relevant metrics within cost-savings, program maintenance costs, community benefit and compliance related domains provide the covered entity with the tools to evaluate and monitor program effectiveness. There is opportunity to expand the dashboard data collection tool to other 340B hospitals in order to help provide national indicators of 340B utilization. Metrics featured in this dashboard can also be utilized to support 340B advocacy efforts and program justification.

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Keywords

340B, Drug pricing, Dashboard, Metrics

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