Healthcare organizations are constantly required to come up with strategies to ensure that all citizens have access to quality and affordable health care services. In essence, for the healthcare sector to achieve in this noble cause it must endeavor to adhere to the best strategy implementation practices. As it is, an effective implementation strategy requires the implementers to involve all the stakeholders, outline the scope of the project, as well as identify the likely risks. Moreover, the implementers must set clear and achievable timelines to reduce wastage and make the project a success. Additionally, there is a need to come up with various assessment tools which will aid the implementers in establishing whether the planned programs are successful or not. In line with these requirements, it is important to consider the “340B Drug Pricing Program Oversight” case to establish whether it made use of the implementation phases.
The “340 Drug Pricing Program Oversight” was an attempt by the federal government to help clients that served patients who were not eligible for Medicaid to get discounts on drugs. The program which is under the Medicaid Drug Rebate Program saw the regulation of prescription drugs manufacturer following the setting of ceiling price for such drugs. Under this program, Medicaid became the preferred prescription drug provider as it offered the best price as compared to other health insurance providers (McLaughlin, & McLaughlin, 2015). The program made use of several implementation phases which is in line with healthcare provisions as evidenced
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Scope
The program established its scope to a great extent in line with the prerequisite implementation phases. In this case, the program was meant for specified healthcare institutions that dealt with specific medical conditions and patients. Specifically, the program targeted eligible clinics which were associated with those hospitals that received disproportionate share payments under, pediatric hospitals, Medicare and community health centers. Moreover, the program was meant to offer the discounted drugs to specialized clinics and projects for hemophilia, HIV/AIDS, tuberculosis, black lung, and family planning. Furthermore, the scope of the project was extended to involve the healthcare institutions that served Native Americans and Native Hawaiians. Additionally, the hospitals that were to benefit from these discounts were supposed to be governmental or nonprofit contracted to provide services supported by the government.
Work Breakdown
For a program to be successful there is a need for the implementers to defines tasks to be completed, individuals to complete them and specific timelines to complete these tasks. Moreover, this phase requires the implementing organization to come up with a master schedule as well as mechanisms to monitor the implementation progress. The 340 Drug Pricing Program Oversight has made use of this phase to a great extent. For one, the strategy tasks the Office of Pharmacy Affairs within Health Resources and Services Administration (HRSA) of the Department of Health and Human Service to administer the program. The main task for this office is to audit compliance with program requirements. In essence, the Office of Pharmacy Affairs is supposed to determine the eligibility of covered entities as well as program integrity to prevent, duplicate discounts diversions and regulate manufacturer pricing (McLaughlin, & McLaughlin, 2015). However, the program has several failures when it comes to the work breakdown. For one it fails to assess the success of the program and in turn relies on participants’ self-policing in ensuring compliance with program necessities. As it is, the program has never done an audit of the covered entities or the concerned drug manufacturers. Consequently, HRSA would not establish where the participants are operating within the confines of the program’ provisions.
Funding
Funding plays a central role in the implementation of healthcare programs. As such it is important for the program planners and implementers to outline their financial obligations as well as the amount of funding that is necessary. Most importantly, the program implementers must be keen to be specific regarding the total or the program is likely to stall which is not economically viable. The “340B Drug Pricing Program Oversight” is not specific on the amount of funding required for the funding (McLaughlin, & McLaughlin, 2015). Perhaps the reason for this is the fact that the program has a very large scope as it targets uninsured Americans. Moreover, the program makes use of federal resources which them makes the funding requirements to be quantified.
Risk Management
Implementation of healthcare programs rides on anticipated risks since the healthcare field keeps on changing to adapt to the prevailing conditions. What is feasible at one time may be unfeasible in future. As such, implementers must make room for the anticipated risks to ensure that the programs achieve the set objectives. The 340B Drug Pricing Program Oversight program rides on the unexpected eventualities. For one the implementers understand that they work with a limited number of staff, which may delay the program implementation to a great extent. In spite of this realization, the project implementers do not establish how they will deal with this risk (McLaughlin, & McLaughlin, 2015). Moreover, the implementers anticipate that the program may not be successful as there is a rapid increase in the number of institutions taking advantage of the said program. The increased institutions may translate to limit funding as the available funding would be overstretched to cater for this unprecedented increase. Additionally, HRSA supports other programs covered by 340B drug discounts, which may cause duplication of roles following a lack of internal capacity furthering the list of anticipated risks (Burton-Meza, 2016). In spite of all these risks, the program fails to specify ways of mitigating the risks or the individuals tasked with the responsibility of dealing with the risks.
Stakeholder Engagement
Program implementation must include stakeholders’ reviews regarding various aspects of the implementation process. As it is, stakeholder engagement is seen as a collaborative and consultative phase in the implementation of healthcare programs. In essence, stakeholder engagement provides the implementers with crucial information regarding the best strategies to adopt. However, it is important to only consider those opinions that will be of use to the program as there is a possibility of getting diverse information during stakeholder engagement (McLaughlin, & McLaughlin, 2015). The “340B Drug Pricing Program Oversight” case has made use of stakeholder engagement though it is not as detailed as it should be. In this case, one is able to establish who the stakeholders are and their role in making the implementation possible. In particular, the program’s implementation stakeholders are the government hospitals and the contracted non-profit medical institutions. These stakeholders have a significant role as they have a say in how they want the program to be implemented since they are at the heart of the program implementation.
Quality Assurance
Program implementers must come up with effective tools to monitor the progress and suggest further improvements into the implementation process. The “340B Drug Pricing Program Oversight” case fails to establish on ways of measuring the success. According to the Senate HELP Committee, (2018), HRSA has never performed an audit of drug the manufacturers or covered entities to assess progress. Instead, HRSA depend on the participants’ self-policing reports to attain compliance with program necessities. This lack of quality assurance procedures puts the program at the risk of becoming unsustainable in the end
Drug Pricing Implementation Strategy
The healthcare sector constantly comes up with programs to ensure that the implementation strategy for drug pricing falls within the accepted provisions. As it is, pricing for therapeutically similar drugs tends to vary significantly, which has prompted both the public and the private insurers to find a middle ground. In essence, an implementation of drug pricing is linked with fluctuations in drug spending and selection on patients who are under employment-based insurance in the US (Licking & Garfield, 2016). When it comes to the implementation of drug pricing strategies, there is a need to involve all the concerned stakeholders in a collaborative and consultative process to enhance consensus. According to Robinson, Whaley, and Brown (2017), one of the pricing strategies adopted in the drug pricing implementation is reference-pricing programs. In this strategy, drugs are classified according to their therapeutic class with payment being limited to the cheapest of the drugs in each category. Patients who may wish to use drugs that are more expensive are expected to pay the difference between the manufacturer’s price and the payer’s limit. Consequently, these pricing strategy helps reduce the cost associated with prescription drugs.
Summary of the Research
Healthcare sector must always find new and innovative ways of ensuring that the public accesses quality and affordable healthcare services. In essence, the concerned healthcare providers must continually plan, implement and monitor various programs to achieve the said objective. One of the most visible health care program aimed at enhancing the quality and affordability of health care services is the “340 Drug Pricing Program Oversight” initiative. This health care program was a government funded and implemented a program aimed at reducing the gap between those who could afford Medicaid and those who would not. In essence, the program aimed at reducing the price of prescription drugs by setting a ceiling price for those drugs. The implementation of the program followed program implementation phases to a great extent. However, the program did not clearly outline the amount of funding needed to enhance its sustainability. Moreover, there were omissions on the aspect of quality assurance which is meant to access the success of the program. Nonetheless, the program can be heralded as it is an attempt to improve the process of healthcare services delivery
References
Burton-Meza, C. (2016). Public health service act, Section 340B: 340B drug discount program compliance risks associated with contract pharmacy arrangements. Journal of Health Care Finance , 1-21.
Licking, E. & Garfield, S. (2016). A roadmap to strategic drug pricing. Invivo: The Business & Medicine Report, 34 (3), 1-11.
McLaughlin, C. P., & McLaughlin, C. (2015). Health policy analysis: An interdisciplinary approach . Burlington, MA: Jones & Bartlett Learning
Robinson, J. C., Whaley, C. M. & Brown, T. T. (2017). Association of reference pricing with drug selection and spending. The New England Journal of Medicine, 377 (7), 658–665.
Senate HELP Committee. (2018). Examining oversight reports on the 340b drug pricing program. U.S. Department of Health and Human Services . Retrieved on 15 September 2018, from https://oig.hhs.gov/testimony/docs/2018/maxwell-testimony05152018.pdf
