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For several years now, Advis has been working closely with Garnet Health. Together, we have focused upon improving compliance and optimizing Garnet’s 340B program. Garnet Health is a non-profit three-hospital health care system located in the mid-Hudson Valley and Catskills region of New York. Serving a large rural and indigent patient population, Garnet Health qualifies for 340B in three different categories based upon its inpatient services: as a DSH hospital, as a Rural Referral Center (“RRC”), and as a Critical Access Hospital (“CAH”). Garnet Health also serves patients through an expansive outpatient network.
Advis is tasked with assisting Garnet Health to ensure 340B compliance for each covered entity. We must ensure that the unique requirements associated with each covered entity are met. Advis also assists Garnet Health with developing strategies that optimize overall program performance. Advis has assisted the Garnet Health team with several projects within its 340B universe, including: implementation of a newly eligible 340B hospital, targeted mock audits, patient sampling assistance, policy and procedure updates, and assisting pharmacy and leadership with 340B day to day operations.
340B services represent a continuous challenge, one that requires strict monitoring and constant oversight. The highly complex and sophisticated nature of the compliance requirements leave many areas open to interpretation. It is important to have resources available to share experiences, best practices, and recommendations, in keeping with the client’s proposed strategy.
At Advis, we strive to assist our clients to meet their strategic objectives. By growing 340B programs while ensuring compliant business practices, we do just that. Best practices and anticipated results are often achieved through our operational assessment procedure, a procedure recently completed at Garnet Health. Our process includes conducting a mock HRSA audit while identifying new strategies to expand and improve the existing program. We take the opportunity to meet with staff onsite, tour the facilities and pharmacy, discuss operations with administrative and clinical staff, and ultimately prepare the hospital for the day when HRSA actually arrives.
Our approach is first and foremost aimed to help Garnet Health remain compliant and to prepare for a HRSA audit. Preparation includes walking through common questions, preparing staff to be comfortable with how to respond to questions, and ensuring full 340B compliance. As a further benefit, we are able to have in depth conversations with the team; we explore real opportunities to expand and improve the extant 340B program.
As a result of our comprehensive operational assessment, the Garnet Health staff were left with an improved sense of program confidence and a sound strategy for increasing 340B savings.
