A. Purpose & Objectives of the RFP The purpose of this Request for Proposal (the RFP) is to invite qualified venders to submit a proposal (or bid) to furnish 340B compliance and support services to the University of California Medical Centers (UCMC). The body of work is envisioned in three phases:(a) an initial, baseline assessment of the compliance of all UCMC 340B activities, (b) a period of remediation and preparation for federal surveys and (c) periodic, ongoing external reviews for 340B program compliance. This bid extends previous efforts by UCSF to obtain these services to now include all UC Medical Centers as listed in Section 1B. 1. 340B operations compliance review- baseline a. Clinics i. Confirmation of clinics eligibility to participate in 340B program ii. Demonstrate compliance with 340B regulations and restrictions b. Confirm accurate billing for MediCaid patients in mixed use areas i. Baseline review of all mixed use areas for allowed patient participation of 340B program ii. Review of the use of split billing software to track patient eligibility iii. Confirm accurate billing for MediCal patients c. UC owned pharmacies i. Trace a sample of prescriptions to assess patient eligibility ii. Determine if adequate diversion mitigation strategies are in place iii. Evaluate patient eligibility filters selected are HRSA compliant iv. Review MediCal billing for application of 340B acquisition price v. Review current specialty pharmacy contracts (if any) with payers for reasonableness vi. Confirm accurate billing for MediCal patients d. Contract Pharmacies i. Trace a sample of prescriptions to assess patient eligibility ii. Determine if adequate diversion mitigation strategies are in place iii. Evaluate patient eligibility filters selected are HRSA compliant iv. Review MediCal billing for compliance with 340B ineligibility v. Advise UC on the negotiating terms and conditions for the contract pharmacy brokers 2. Preparation for Federal Audits a. Policy and Procedures i. Evaluate adequacy of current Policies & Procedures and make recommendations for improvement ii. Review the current internal compliance review strategies and test for adequacy For any areas identified as non-compliant in the baseline review, provide direction and guidance for efficient and expedient change to ensure compliance. Ensure the medical center is prepared with the materials reasonably expected for a federal audit (reports, documents, etc) 3. Ongoing audits of 340B Compliance, not less than quarterly a. Specific program to verify appropriate 340B compliant patient service, product replacement, and billing for external partner pharmacies acting as an official contract pharmacy to UCMC b. Regular review of 340B compliance relative to dynamic regulatory updates and business developments internally, The services will be offered to each medical center that requests to join this effort. Though contracted from UCOP Health Sciences and Services (HSS) the service client will be each UC medical centers chief financial officer (CFO) working with their medical center pharmacy management. It is desired to find a service provider that can drive economies and value through the collaboration of UCMC if a single supplier is selected. Responses to this RFP should demonstrate a breadth of knowledge and experience commensurate with the need to guide UCMC towards efficient and complete compliance with the 340B program. In addition, there should be clear evidence that services can be delivered to UC in an efficient, and economical fashion.
