Quick Q&A with Rx|X Founders
What inspired you to start Rx|X?
Suzanne: We started Rx|X to focus on working with covered entities. Prior to starting Rx|X, Madeline and I had worked together for years. Starting Rx|X was a way to take our experience and more directly assist covered entities with 340B. We approach audits and compliance from our training as program evaluators, who consider a wide variety of methods when designing how to tackle a project.
Madeline: Yes, after years at the OIG examining how HRSA was running the 340B Program, we shifted to working with covered entities, providing technical support for three years via APhA’s contract with HRSA. We helped oversee the peer-to-peer program, wrote policy papers for areas of interest for OPA, and resolved issues for entities. For us, our favorite part was interacting with the 340B teams in the field and we wanted to focus on that. Things really took off for us after the 2013 GPO policy update for hospitals and increased HRSA audits.
In your opinion, what is the biggest misconception about the 340B Program?
Madeline: That there is no oversight or investment in compliance from covered entities. We see the complete opposite. It takes an incredible effort to coordinate a program that touches nearly all departments and faces risks from multiple stakeholders. The data production for a HRSA audit is intense and the on-site and any follow-up requires all hands on deck for an average of three months.
Suzanne: 340B does not increase prices paid by patients, insurance, or the government. 340B is a cost reduction program. It reduces the price at which drugs are purchased. The program was intended to decrease drug prices for covered entities to offset price increases resulting from the Medicaid Drug Rebate Program. If you remove 340B, the prices for covered entities will inevitably go up as they did in the early 90s.
How do Rx|X’s audits differ?
Suzanne: Rx|X audits are not typical mock HRSA audits. While being ready for a HRSA audit is important, we believe that covered entities should be prepared to answer inquiries from any 340B stakeholder (HRSA, States, manufacturers, government) and fully understand their operations. Therefore, we guide our clients on how to best organize data from the foundation up to build a strong program. Data organization and understanding the purpose of what you are submitting are key elements to preparing for a successful audit!
Madeline: We spent a lot of time thinking about a modern approach to 340B audits. Over the years, we have iteratively created a specific way of organizing data and educating clients on how seemingly disparate pieces of data influence each other. It is rewarding to see new analysts connect the dots and demonstrate curiosity around other departments or technology! In addition to the basics, we developed a novel audit tool, Avanti340B, where we take all purchases, dispenses, and accumulations each quarter and reconcile data for optimal performance.
Speaking of, how do you see Rx|X’s new tool, Avanti340B, streamlining internal processes for clients?
Suzanne: Simply put, Avanti340B provides really powerful analytics to the 340B team. The Rx|X team receives data, inputs it into Avanti340B and provides reports that help covered entities identify issues that cannot be identified through transaction testing. The tool uses data outside of the split billing software to independently test compliance with 340B program requirements, as well as areas for improvement.
Madeline: To say that 340B involves a lot of data is a massive understatement. After decades looking at such data and identifying how transaction testing just isn’t enough, we developed Avanti340B. This software ingests data for all NDCs across all accounts and reveals so much about purchasing patterns, data connections, and other critical aspects of the program. Since pharmacy is ever-changing, we developed several standard reports in the tool to guide actionable items for clients each quarter.