October 18 – 24 is National Pharmacy Week. Throughout the week, CompleteRx celebrates frontline teams and individuals who go above and beyond in a series of blog posts.
For Victoria Nosowicz, CphT, pharmacy informatics and 340B manager for Upper Allegheny Health System, the pharmacy profession is in her blood. She began her first pharmacy job as a senior in high school, working alongside her pharmacist father, and never left the profession.
“It just kind of stuck and I’ve grown from there,” she says.
In her current role, Nosowicz handles all of the health system’s pharmacy data related to the electronic medical record, Pyxis and most of the ancillary systems. She also has responsibility for the system’s 340B program. Upper Allegheny Health System is a two-hospital system serving residents of northwestern Pennsylvania and southwestern New York. The hospitals serve predominantly rural areas.
A new opportunity
Nosowicz attended the 2020 340B Coalition Winter Conference last February in San Diego, California. During the conference, she learned about a 340B opportunity related to referral prescriptions that had the potential to capture significant additional savings for Upper Allegheny.
Under the 340B program, a covered entity’s providers may refer patients out to specialists for care at a location that is not 340B eligible, such as a specialist’s private office. If the specialist writes a prescription for the patient as a result of the referral by the covered entity’s provider, those prescriptions are considered referral prescriptions, which can qualify as 340B eligible.
Few covered entities capture the savings for prescriptions written by a specialist outside a covered entity because it can be labor intensive to prove ownership of the patient’s care and referral prescriptions. “I’ve heard some entities mention they’ve attempted it or looked into it, but I’m not aware of anybody actually implementing a program to capture referral prescription savings,” says Nosowicz.
Typically, the covered entity must have documentation of an outgoing referral in the patient’s medical record on or before the date of the referral prescription. After that, the covered entity must receive visit summary notes to be uploaded into the patient’s medical record to corroborate the eligibility of the referral prescription.
So, why did Nosowicz decide to embark on this new initiative? “I like a good challenge,” she says laughingly. “This seems like a great opportunity to expand the services we can offer to patients through our 340B program. As a hospital serving a rural community, it’s the right thing to do.”
Preparing to launch the prescription referral program
After conducting an initial review of referral prescriptions, Nosowicz estimates the program will save the health system just over one million dollars in the first year, as she and the team “work out the kinks.” As the program matures, Nosowicz expects to achieve additional savings.
She is currently designing the program’s workflow and working on hiring a coordinator to manage and document the health system’s 340B referral prescriptions. A big part of the coordinator’s role will be conducting internal audits and ensuring referral prescriptions are identified and qualified compliantly.
“I’m hoping we’ll be off and running by the end of the year,” says Nosowicz.
CompleteRx extends a warm “thank you” to Victoria and the team at Upper Allegheny for their continued hard work and innovative thinking!