Covered entities participating in the 340B Drug Pricing Program must ensure program integrity and maintain accurate records documenting compliance with all program requirements. They are subject to audit by the manufacturer or the federal government. Failure to comply may make the 340B covered entity liable to manufacturers for refunds of discounts or cause the covered entity to be removed from the 340B program.
Why Name, Rank, and Serial Number Reference Policies are a Double-Edged Sword
Organization leaders and Human Resources professionals are often challenged by walking the tightrope of when to share information about former employees and when to stick to facts providing only dates of employment, title, and wage. As a result many organizations have policies that closely define those who are approved to release employment information and what information they are allowed to release regarding a former employee.
Job Descriptions as Performance Appraisal Forms… The Ideal Solution
Performance appraisal may well be the most despised management process around, and often for very good reasons. Most performance appraisal forms are only marginally relevant to an employee’s job, and the results of the process itself yield very little – perhaps a token difference in a raise for a “higher performer” over a “lower performer;” but even these distinctions are often criticized by employees because of assumptions concerning how “tough” one supervisor is over another. Simply put, the link between actual performance and actual executive or employee compensation is frequently tenuous at best.
Are You Considering Expansion Into Mobile Care?
Many health centers are now incorporating mobile clinics as a key strategy for improving access to health care, especially in rural areas, farmworker communities, housing projects and homeless populations. Mobile clinics help overcome barriers, such as transportation, that prevent people from accessing health care. A mobile unit can also be more flexible so care can be provided during non-traditional hours such as evening and weekends.
FQHCs Collected Up-Front, When Up-Front Wasn't Cool
Breaking NPR news, "With Medical Debt Rising, Some Doctors Push For Payment Upfront." Medical practices are feeling the crunch, so they are making patients pay their copays before they are seen. Welcome to our world.
340B DOES Benefit the Patient!
Congress created the 340B program in 1992 to help uninsured indigent patients gain better access to prescription medications and to allow health centers stretch scarce federal resources. The 340B program is vitally important for safety net providers and their most vulnerable patients. It lowers drug costs for providers, allowing them to pass along these savings to their patients and maintain and expand other health care services. Congress intended for covered entities to use the benefit of the discount to reach more eligible patients and provide more comprehensive services, and the 340B program has met these essential goals.
The Importance of a Gift Acceptance Policy for an FQHC - Part 2 (Screening Gifts)
“The NLRB said what? We were certain our Human Resources functions were legal”
Do your policies and/or employee handbook forbid your employees from sharing information about their own wage and benefit packages with other employees? If so, it’s important to note that the National Labor Relations Act (NLRA) has a different opinion and your health care facility might be found in violation by the National Labor Relations Board (NLRB). As a consultant providing services to health care organizations on matters of human resources and health care compliance, I often find employers with policies that put them at risk.
Your Employment Budget is too Precious to Waste on the Wrong People
As every one of my clients has heard at one time or another, I plan on writing a book some day, and it’s going to have a chapter entitled “management spends 95% of its time on the 5% of its employees that provide the least value.” I will certainly need a more pithy chapter title at some point, but be patient with me for now. Some time into our discussions, people eventually nod their heads and say “yes, that’s true,” and then often launch into a conversation about the number of times that has happened to them. Unbeknownst to them (but beknownst to us!) we are now adding on to the time we’ve wasted on those same people, well after they are gone. The corollary to the chapter title is an exercise in simple math, which breaks down to: “we spend almost no time on our best people.”
I could just stop there.
But I won’t.
More than 7 Million Enrolled, But Who Will Provide Their Care?
More Than 7 Million Sign Up for Health Coverage, the headlines boast.
However, just as millions of Americans are obtaining insurance coverage through the federal health law, many primary care doctors are retiring early, converting their practices to concierge or joining large healthcare and hospital groups. The primary care physician, also known as a “provider,” may be headed toward extinction.










