1. New Jersey Society of Oncology Managers
Federal Health Policy: How It May Impact Your Program Part Two
June 19, 2018

2. Agenda Provider-Based Billing Financial Considerations
The purpose of this presentation is to summarize key features of the 340B Drug Pricing Program and to discuss potential implications associated with a hospital partnership to access the program. I.
340B Primer
II.
Provider-Based Billing
III.
Financial Considerations
IV.
Alignment Models V.
Questions and Discussion
Attachment A: Common Treatment Regimens
DPC NOTE
DO NOT DELETE
6/11/18, Sarah T.:
att A in this PPT.
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3. I. 340B Primer Overview and History
The 340B program was established by section 340B of U.S. Public Law , the Veterans Health Care Act of Its purpose is to limit the cost of covered drugs to certain federal and qualified entities.
The program “requires drug manufacturers to [sell] outpatient drugs to eligible covered entities (healthcare centers, clinics, hospitals) at significantly reduced prices” determined using a statutory formula.
Further, 340B is intended to “enable covered entities to stretch scarce Federal resources as far as possible, reaching more eligible patients and providing more comprehensive services.”
The Health Resources & Services Administration (HRSA) Office of Pharmacy Affairs administers the program.
In January 2010, 340B eligibility was expanded to include children’s hospitals, Critical Access Hospitals (CAHs), freestanding cancer hospitals, rural referral centers (RRCs), and sole community hospitals (SCHs).
Source:
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4. I. 340B Primer Eligibility Criteria
Over 12,000 healthcare facilities have been certified eligible by the U.S. Department of Health & Human Services (HHS). The following types of facilities are eligible as covered entities:
Consolidated health centers
Community health centers
Migrant health centers
Healthcare for homeless
Public housing primary care
School-based health centers
AIDS clinics and drug programs
Black lung clinics
Federally qualified health center look-alikes.
Urban Indian clinics/638 tribal centers
Title X family planning clinics
Disproportionate share hospitals (DSHs)
CAHs
Freestanding cancer hospitals
RRCs
SCHs
Hemophilia treatment centers
Native Hawaiian health centers
STD clinics
TB clinics
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5. I. 340B Primer Eligibility Criteria: DSH
In the oncology community, most hospitals qualify for 340B based on their DSH status. Requisite DSH percentages vary by type of hospital.
Medicare DSH Adjustment Provision
The DSH provision was enacted by and became effective for discharges occurring on or after May 1, 1986.
The purpose is to identify hospitals that give treatment to a high number of uninsured, underinsured, and Medicaid patients.
While the general rule for hospitals is a DSH percentage of at least 11.75%, CAH, RRC, and SCH organizations must have a DSH in excess of 8%.
DSH Calculation
It is based on the overall facility payor mix.
The DSH patient percentage is calculated by the following:
(Medicare SSI Days ÷ Total Medicare Days) + (Medicaid, Non-Medicare Days ÷ Total Patient Days)
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6. I. 340B Primer Eligible Drugs and Patients
Patients must meet prescribed criteria in order to be eligible to receive 340B medications.
Eligible patients are defined as patients who meet all of the following guidelines:
Established Relationship: The covered entity has established a relationship with the individual, such that the entity maintains records of the individual's healthcare.
Responsible for Care: The prescription is for a condition for which the individual is currently receiving healthcare services from a healthcare professional. This professional either is employed by the covered entity or provides healthcare under contractual or other arrangements (e.g., referral for consultation), such that responsibility for the care provided remains with the covered entity.
More Than a Referral: An individual will not be considered a “patient” of the entity for the purposes of 340B if the only healthcare service received by the individual from the covered entity is the dispensing of a drug(s) for subsequent self- administration or administration in the home setting.
It is illegal to sell or provide 340B-priced drugs to persons who are not patients of a covered entity.
Currently, vaccines and inpatient drugs are not covered under 340B.
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7. I. 340B Primer In-House Pharmacy
Covered entities must have an in-house pharmacy or agree to a contract with a community pharmacy to dispense the drugs.
In-House Pharmacy: The covered entity buys drugs at “the 340B price” (or lower, if the deeper discount is negotiated with the manufacturer by a prime vendor or entity) through its wholesaler. These guidelines must be followed by participants with an in- house pharmacy:
Covered Outpatients with Third-Party Prescription Coverage: Copay and pharmacy reimbursement are administered according to the insurer’s policy.
Medicaid Patients: The entity must choose a procedure that prevents duplicate discounts. The two options are as follows:
The state has the entity’s Medicaid provider number in the exclusion file. The entity bills Medicaid at “acquisition cost” plus the state-allowed dispensing fee, and the state does not request a rebate.
The entity carves out Medicaid drugs from the 340B program and allows the state to collect rebates and must notify the 340B Office of Pharmacy Affairs.
Uninsured Patients: The entity determines what the patient pays, often on a sliding scale, subsidized by 340B savings from other patient transactions.
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8. I. 340B Primer Contracted Pharmacy
Contracted Pharmacy: A covered entity is allowed to contract with a pharmacy to dispense 340B drugs and provide pharmacy services to the entity’s patients. These guidelines must be followed by participants with a contracted pharmacy:
The pharmacy must provide the entity with reports “consistent with customary business practices.”
The entity and pharmacy are subject to audits.
The entity and pharmacy must comply with all federal and state laws.
It does not require dual physical inventory.
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9. I. 340B Primer Potential for 340B: Timeline
Typically, it takes about 6 to 18 months to begin administering 340B drugs in a new site (generally about 6 months following the end of the cost report fiscal year).
340B Implementation Process
Clinic Conversion: Complete formation of a provider-based clinic (provider credentialing, facility renovations, etc.).
Attestation: Submit the provider-based entity (PBE) attestation and CMS-855A form to Medicare in order to add the new clinic location and begin billing as a provider-based clinic.
Cost Report: At the end of the current fiscal year, submit a cost report to CMS, including expenses for the new clinic site.
HRSA Application: Following submission of the cost report, the hospital may submit an application to HRSA to add a new clinic site during the next quarterly window.
Commence Operations: After the application is approved, the hospital could begin utilizing 340B medications in the clinic.
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10. I. 340B Primer Registration
Once it has been determined that the organization is eligible to participate in 340B, it must be formally enrolled, and there are limited 340B registration windows.
In order to participate in 340B, eligible organizations/covered entities must register, be enrolled, and strictly comply with all requirements.
Covered entities are assigned a 340B identification number that vendors verify before allowing an organization to purchase 340B discounted drugs.
New registrations are only accepted during the following time periods, which then determine the effective date for participation in 340B:
Registration Date
Effective Date
January 1–15
April 1
April 1–15
July 1
July 1–15
October 1
October 1–15
January 1
Source:
For many organizations, meeting the requirements associated with conversion to a hospital outpatient department (HOPD) will determine the implementation timeline.
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11. I. 340B Primer Legal Considerations
Before enrolling in 340B, it is important to consider all applicable rules and regulations.
Stark law
Chemotherapy is considered a designated health service; this designation limits physicians’ ability to invest in chemotherapy businesses.
HOPPS
The infusion clinic will be subject to HOPPS (PBE) rules rather than MPFS rules.
Presence: Physician presence requirements must be followed.
Licensing: Hospital licensing requirements (department of health, the Joint Commission) must be followed.
Operation: The clinic must be operated by the hospital.
Location: The clinic must be within 35 miles of the hospital’s main campus but does not need to be on the campus. However, requirements vary for off- campus clinics (greater than 250 yards from the primary address of hospital).
Billing: Services must be billed by the hospital, and the hospital must buy/provide the drugs.
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12. II. Provider-Based Billing Provider-Based Versus Freestanding Clinics
Attaining provider-based status requires that clinics comply with a host of regulations. All of these requirements listed below are from the perspective of an organization participating in the 340B program.
On-Campus, Provider-Based Clinic
Off-Campus, Provider-Based Clinic
Freestanding Clinic
Owned and operated by the hospital.
Location: Within 250 yards of the main campus.
Integration: Medical records, patient services, and finances must be integrated with the main campus.
Staff: Must be hospital employees or leased from physician office practices.
Public Awareness: Represented to the public and payors as a hospital clinic.
Hospital/Hospital Joint Venture: Permissible under certain circumstances; must be provider- based only for the owner of the campus.
Same requirements as for an on- campus clinic except:
Located within 35 miles of main campus.
Clinical (nonphysician) staff must be hospital employees.
No joint venture ownership is permitted.
Additional requirements include the following:
Professional staff must have privileges at the main campus.
Hospital must have 100% ownership and operational control over the clinic.
Clinic must have the same supervision as any other provider department.
The clinic and the hospital must have same governing body.
Can be owned and operated by physicians.
Cannot be classified as an HOPD and therefore does not qualify for 340B pricing.
Presently, patients can be referred to the hospital’s infusion clinic, but this practice is under review and therefore may change.
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13. II. Provider-Based Billing Provider-Based Definition
To further clarify, “provider-based” and “freestanding clinic” are Medicare designations that determine Medicare payments to outpatient clinics.
Medicare uses the terms “provider-based” and “freestanding” to denote who owns and operates ambulatory clinics and how they are billed.
Freestanding Clinics
Provider-Based Clinics
Physicians
Hospital
Physicians own and operate the clinic and bill Medicare globally.
The hospital owns and operates the clinic and bills Medicare.
Physicians
Physicians practice in the clinic and bill Medicare.
Freestanding (also known as physician-based, office-based, nonfacility, or Place of Service [POS] 11) refers to a clinic that is owned and operated by physicians and bills Medicare globally.
Provider-based (also known as hospital-based, facility, or POS 22) refers to a clinic that is owned and operated by the hospital, and both the hospital and physicians bill Medicare.
In order to participate in 340B, an entity must be enrolled as a provider-based clinic.
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14. II. Provider-Based Billing Provider-Based Status/CMS Requirements
Professional staff at the facility have clinical privileges at the hospital.
The hospital maintains the same monitoring and oversight of the facility as it does for any other department.
Medical records for patients treated in the facility are integrated with those of the main hospital.
The clinic meets applicable facility requirements under state law.
Clinical Integration
Clinical services of the facility and main hospital are integrated.
Income and expenses are shared.
Costs arising from the facility are reported in the appropriate cost center of the hospital.
Financial status of the facility should be incorporated and readily identified in the hospital’s trial balance.
Financial Integration
The financial operations of the facility are fully integrated within the hospital’s financial system.
Patients must be aware that they are entering the provider’s facility and will be billed accordingly.
This provision will likely require changes to clinic signage and branding.
Notification to other payors is also required.
Public Awareness
The PBE is presented to the public and other payors as part of the main hospital.
These regulations greatly influence the design of potential physician partnership models.
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15. III. Financial Considerations Common Treatment Regimens: 340B Savings
According to MedPAC’s 2015 report on the 340B Drug Pricing Program, the average drug savings rate for 340B providers is approximately 30%. Applying this savings rate to common treatment regimens for breast, lung, and colon cancers illustrates the magnitude of impact these savings can have on oncology providers.
Tumor Site
Regimen
Treatment Cost without 340B Savings
Treatment Cost with 340B Savings
Treatment Cost Savings Variance with 340B Pricing
Breast
Avastin
$7,176
$5,023
$2,153
Lung
KEYTRUDA
$5,858
$4,101
$1,758
Colon
FOLFOX 1
$595
$417
$179
1 FOLFOX is a combination of the following chemotherapy drugs: folinic acid (also called leucovorin, FA, or calcium folinate), fluorouracil (5 FU), and oxaliplatin.
See attachment A for further detail about these treatment regimens.
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16. III. Financial Considerations Potential Programmatic Impact
The benefits of 340B can be especially profound for cancer clinics due to the typically high cost and high volume of chemotherapy medications.
The impact of providing chemotherapy for one physician’s patients is significant.
The 340B program typically yields 20% to 40% savings in drug costs.
Medical oncologists typically generate $2.5 million to $3.5 million in drug expenses annually.
The reduction in costs, per physician, typically ranges from $500,000 to over $1 million per year.
In addition, provider-based billing often yields a meaningful revenue increase from Medicare, often more than $100,000 per physician.
With the exception of Medicaid, third-party reimbursement is unaffected by the cost of the drugs; therefore, the cost savings translate directly into enhanced margins. However, some savings may be offset by higher costs incurred in the hospital versus freestanding clinics.
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17. III. Financial Considerations Changing Reimbursement: Bipartisan Budget Act of 2015
The Bipartisan Budget Act of 2015, signed into law by President Obama on November 2, 2015, changed the financial and operational implications of facility-based Medicare reimbursement.
New off-campus HOPDs will no longer receive a site-of-service payment differential.
After January 1, 2017, new HOPDs will be reimbursed at a rate that is approximately 50% less than the old HOPPS rate, in order to approximate the Medicare Physician Fee Schedule.
Description
Important Details
On-campus outpatient departments are not affected.
An on-campus outpatient department is defined as an area within 250 yards of a main campus.
Only those sites billing as an HOPD by November 2, 2015, will continue to be reimbursed at the full HOPPS rates.
New sites will still be eligible to participate in the 340B drug program.
Commercial reimbursement is not yet impacted.
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18. III. Financial Considerations 340B Reimbursement Changes
The CY 2018 Outpatient Prospective Payment System (OPPS) rule released in November 2017 confirms changes to 340B reimbursement that will have a major impact on safety net hospitals. This change is not surprising, given the Trump administration’s focus on controlling drug costs.
ASP1 Plus 6%
Current methodology
340B Payment Reduction: 26.9%
Brings reimbursement more in line with acquisition costs
CMS Estimated Annual Savings: $1.6 Billion
Will be used to increase overall payment rates to all hospitals for nondrug items and services paid under the OPPS
ASP Minus 22.5%
New methodology, based on MedPAC’s 2015 estimate of the average minimum discount on 340B drugs
1 ASP based on data submitted by drug manufacturers.
Source:
Note that the rule does not alter how drug manufacturers set prices, nor does it address concerns regarding the perceived lack of oversight of the 340B program.
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19. III. Financial Considerations Inclusions and Exclusions
DSHs and RRCs are affected by the change. Although there is a set of organizations excluded from the rule, these exemptions are only confirmed through CY 2018.
DSHs and RRCs enrolled in the 340B program
Part B, separately payable, non-pass-through drugs and biologicals purchased through the 340B program
CAHs, children’s hospitals, the 11 PPS-exempt cancer hospitals, and rural SCHs
Part D drugs and vaccines purchased by 340B covered entities
What’s In?
What’s Out?
Note: These exemptions are only valid through CY CMS has stated that it may consider revisiting the rule after CY 2018.
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20. III. Financial Considerations Revenue Loss Implications
Given the volume of high-cost drugs administered by cancer programs, there is an estimated annual loss of revenue (and attendant net income) of up to $500,000 per medical oncologist in hospital-based cancer programs.
This change will reduce an important revenue stream used by many 340B participating hospitals to support uncompensated care, support services, and other unprofitable programs.
Patient navigators
Transportation services
Physical and occupational therapy
Psychosocial support
Nutrition counseling
Financial counseling
Support groups
Illustration of Lost Revenue
Calculation Key
Low Scenario
High Scenario
Medical Oncology FTEs A 5
Average Oncology Drug Spending per Physician FTE1 B
$3.1 million
$3.6 million
Estimated 340B Reimbursement Cut Impact2 C
26.9%
Estimated Medicare Payor Mix D
50.0%
Economic Loss per Physician
E = B × C × D
$416,950
$484,200
Total Revenue Loss
F = A × E
$2.1 million
$2.4 million
1 “The National Practice Benchmark for Oncology,” Journal of Oncology Practice. Low scenario based on 2014 report based on 2013 data. High scenario based on 2015 report based on 2014 data.
2 Rate of payment reduction from 106% of ASP to 77.5% of ASP.
Realized impact will differ based on variables such as provider productivity, payor mix, case mix, and drug acquisition costs.
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21. III. Financial Considerations Litigation Activities
Although the reimbursement changes have gone into effect, legal activities are under way to contract the scope of the regulation.
Litigation
Litigation to stop payment cuts was filed by hospital associations and 340B hospitals.
The case was dismissed on December 29, 2017.
The judge ruled that the plaintiffs did not have standing to file the suit.
The judge did not rule on the merits of the case.
An appeal was filed in early January 2018.
Expect continued litigation following payment of a claim at the reduced rate.
Underlying legal issues are related to administrative law as well as the intent of the 340B program.
Recent Developments: March 2018
Plaintiffs filed court papers detailing the significant impact of the 340B cuts.
HHS filed a brief defending the cuts on March 20.
The plaintiffs’ response was due by April 2, and oral arguments in the case took place on May 4.
DPC NOTE
DO NOT DELETE
5/29/18, Rene D:
Please leave Times New Roman font in graphic
In Court Papers, 340B Hospitals Tell How Massive CMS Cuts Are Causing Irreparable Injury
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22. III. Financial Considerations Legislative Activities
Several legislative activities aimed at eliminating or slowing down Medicare cuts to 340B are also under development.
Legislation
Multiple legislative efforts are in process, including the following:
HR 4392: This would prevent CMS from implementing the payment cuts; it has significant bipartisan support.
HR 4710 (340B PAUSE Act): This would impose a two-year moratorium on new 340B DSHs and locations and would also require for DSHs, cancer hospitals, and children’s hospitals: (1) additional data reporting, (2) OIG study on charity care, and (3) GAO report on hospital/government contracts and 340B revenue.
S 2312 (HELP Act): It would also impose a two-year (possibly longer) moratorium on new 340B DSHs and locations. This law is similar to but more comprehensive than HR 4710.
Areas of focus for new legislation include the following:
Strong focus on 340B-participating hospitals (not on grantees) and limitations on patient eligibility
Limits on amounts that could be charged for 340B drugs
Limits on contract pharmacies by number and location
Required reporting of the amount and use of 340B savings
The uncertainty and risk currently associated with the 340B program is likely to continue in the foreseeable future.
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23. IV. Alignment Models Physician Response
In response to continued economic pressures, physician practices are adopting a number of strategies to remain competitive and economically viable.
Economic Pressure: In response to the ongoing economic pressure, oncology practices have adapted in order to continue providing services to most patients. Adaptations include:
Gains in efficiency.
Reductions in physician-owner compensation.
Greater selectivity of patients (e.g., payor mix preferences).
Tighter management of drug spending/inventories.
Expanded Service Offering: Many oncology practices have expanded or are expanding their portfolio of lucrative outpatient modalities (radiation therapy and imaging).
Hospital Affiliations: Oncology remains a financially profitable service line for most health systems. Often, affiliation with a health system’s oncology service line has a variety of clinical, strategic, and financial benefits for a group.
Sources: The Advisory Board Company, “Oncology State of the Union” and Thomas R. Barr, MBA, COO, Oncology Metrics, “State of the Industry and Trends: Practice Perspective,” 2009 Cancer Center Business Summit, Washington, DC, Sample size of 208 oncology practices.
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24. IV. Alignment Models Overview
There is a spectrum of potential affiliation models that may satisfy the various affiliation goals and objectives.
Limited Comanagement Arrangement
Infusion Acquisition and Comanagement
PSA1 and MSA2
PSA
Employment
Degree of System/ Physician Integration
Loosely Integrated
Tightly Integrated
1 Professional Services Agreement (PSA).
2 Management Services Agreement (MSA).
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25. IV. Alignment Models Limited Comanagement Arrangement
In a limited comanagement model, the scope of the arrangement may be restricted based on payor class, patient diagnosis, or other criteria. Private physicians would provide oversight and medical direction to the hospital-based infusion therapy program.
Hospital
Infusion Clinic
Physicians
Contract for Physician
Oversight at the Infusion Clinic
Medication purchased under the 340B program
Physicians Clinic
The financial benefits and the degree of integration achieved through this model are limited.
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26. IV. Alignment Models Limited Comanagement Arrangement (continued)
In this model, the hospital and physicians are loosely integrated. Patients are seen both at the hospital infusion clinic and the private clinic, with 340B benefits available only to patients receiving infusion therapy at the hospital infusion clinic.
Select patients (at the discretion of physicians) are treated at the hospital infusion clinic.
Medications purchased under the 340B program would be provided only to patients treated in the hospital infusion center.
Other patients would continue to receive therapy at private clinics.
In conjunction, the hospital would contract with physicians to provide management services to the center for an FMV fee.
In contrast to the next model, both the hospital and physicians continue providing infusion services in this option.
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27. IV. Alignment Models Infusion Acquisition and Comanagement
In this model, the hospital would acquire physicians’ chemotherapy services at FMV and then contract with physicians to provide services to the hospital.
Hospital
Infusion Clinic
Physicians
Management
Services
Comanagement
Compensation
Acquisition and Transfer of Infusion Business
Payment for the infusion business may be structured as a lump sum or paid in installments. The value of the business will be tied to the duration of the noncompete agreement with physicians.
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28. IV. Alignment Models Infusion Acquisition and Comanagement (continued)
In this model, physicians’ practice is bifurcated. The group will continue to provide professional services, but the hospital will supply all infusion therapy services.
The hospital acquires physicians' infusion therapy services and would contract with physicians to provide clinical and administrative management services (e.g., clinical oversight, physician presence, management of drug inventory, participation in developing guidelines) to the hospital for an FMV fee.
Physicians may continue to own certain practice assets (e.g., infusion chairs, electronic medical record system, office space and/or tenant improvements) and lease them to the hospital.1
So long as the clinic meets on-campus requirements, clinical staff may remain employed by physicians, which in turn may contract their services to the hospital.1
Physicians may provide certain management services for the infusion business (e.g., patient registration, reception, billing).1
Under this model, only the infusion therapy business would be converted to a PBE.
Physicians agree not to compete with the hospital for infusion services for the term of the arrangement.1
1 Subject to legal guidance.
There are number of challenges to consider with this model, such as the structure of noncompete agreements, the term of the deal, and unwind and refresh provisions.
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29. IV. Alignment Models PSA
Under the PSA model, the hospital would contract for professional services from physicians.
Medical
Group Board
Hospital
Clinical Services
Physicians
PSA
Compensation
Contracting
Billing
Managed care administration
Recruitment
Research/education support
IT support
Staffing and management
Clinic operations
Asset ownership
Group governance
Physician hiring/termination
Clinical coordination
Internal compensation distribution plan
Management Committee
Strategy/finance approval
Operations/business planning oversight
Input on personnel management decisions
Physician recruitment initiatives
Clinic financial management oversight
Development and approval of clinical protocols and management of procedural compliance
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30. IV. Alignment Models PSA (continued)
The PSA is a contract between the hospital and physicians. This model would more tightly integrate physicians with the hospital compared to prior models.
The contract defines the overall compensation pool, the services provided by both parties, and the governance mechanism for decision-making.
The hospital pays physicians aggregate compensation through the PSA; the group typically controls distribution at the individual level.
The physicians provide professional services and may comanage other aspects of the cancer program.
The hospital manages the clinics and other components of the cancer program.
The management committee is empowered through the contract to engage in group/service line planning and budget approval.
Physicians maintain their governance structure and are responsible for overseeing clinical issues and determining the group’s income distribution.
All clinic staff and practice managers are employed by the hospital.
The PSA model may also be combined with the infusion acquisition and comanagement model.
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31. IV. Alignment Models PSA and MSA
In the PSA and MSA model, the group may retain various clinic assets, employment of staff, and management of operations. The scope of these arrangements can vary greatly.
Medical
Group Board
Clinical Services
Hospital
PSA
Physicians
Compensation
Management
Services
MSA
Compensation
Strategy/finance approval
Overall governance
Payor contracting
Group governance
Physician hiring/termination
Clinical coordination
Internal compensation distribution plan
Operations/business planning oversight
Various Services That May Be Provided by Either Organization
Billing and Collections
Credentialing IT
Staffing and Management
Asset Ownership
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32. IV. Alignment Models PSA and MSA (continued)
The PSA and MSA model allows the hospital and physicians to work together to build a program but maintains a high level of autonomy for the physicians.
The hospital would contract with physicians for clinical services and management services through a PSA and an MSA, respectively.
The contracts would define compensation, the services provided by both parties, and the governance mechanism for decision-making.
Physicians would be paid FMV compensation for clinical activities and program development through the PSA.
Physicians would be compensated at FMV for the management of the clinic, the leasing of specific staff, and potential quality incentives through the MSA.
The practice’s ownership and infrastructure would remain independent and under the control of the physicians, and the physicians could still own the tangible and intangible assets of their practice.
The PSA and MSA would have terms usually lasting two to three years and would provide an exit opportunity at the end of the contracts.
The terms in the PSA would need to reflect PBE regulations (e.g., reporting structure, employment requirements).
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33. & Questions Discussion Matt Sturm msturm@ecgmc.com 206-689-2243
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34. Attachment A
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35. Common Treatment Regimens: Avastin
With 340B drug pricing, savings for a course of treatment of Avastin is over $2,000.
Breast Regimen: Avastin
Drug
J Code
Drug Cost per Unit without 340B
Drug Cost per Unit with 340B
Total Units Billed per Treatment
Treatment Cost without 340B
Treatment Cost with 340B
Treatment Cost Savings with 340B
Avastin
J9035
$71.80
$50.23
100
$7,176.00
$5,023.00
$2,153.00
Note: Figures may not be exact due to rounding.
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36. Common Treatment Regimens: KEYTRUDA
With 340B drug pricing, savings for a course of treatment of KEYTRUDA is approximately $1,760.
Lung Regimen: Keytruda
Drug
J Code
Drug Cost per Unit without 340B
Drug Cost per Unit with 340B
Total Units Billed per Treatment
Treatment Cost without 340B
Treatment Cost with 340B
Treatment Cost Savings with 340B
KEYTRUDA
J9271
$46.49
$32.54
126
$5,858.00
$4,101.00
$1,758.00
Note: Figures may not be exact due to rounding.
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37. Common Treatment Regimens: FOLFOX
With 340B drug pricing, savings for a course of treatment of FOLFOX is approximately $180.
Colon Regimen: FOLFOX
Drug
J Code
Drug Cost per Unit without 340B
Drug Cost per Unit with 340B
Total Units Billed per Treatment
Treatment Cost without 340B
Treatment Cost with 340B
Treatment Cost Savings with 340B
5FU: Adrucil
J9190
$1.55
$1.08 2 $ $ $ 9
14.00
10.00
5.00
Aloxi
J2469
$18.15
$12.70 10
182.00
128.00
55.00
Decadron
J1100
$0.10
$0.07
1.00
Oxaliplatin
J9263
$0.22
$0.15
300
65.00
46.00
20.00
Emend
J1453
$1.93
$1.35
150
291.00
204.00
88.00
Leucovorin
J0640
$2.92
$2.04 14
41.00
29.00
13.00
Regimen Total
$595.00
$417.00
$179.00
Note: Figures may not be exact due to rounding.
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