ACE Purchasing & Inventory Management 1 — Questions and Answers
Question 1: What is the primary tool for covered entities to purchase 340B drugs at discounted prices?
- Medicaid Drug Rebate System
- Manufacturer Direct Purchasing
- Prime Vendor Program (PVP) (Correct answer)
- CMS Price Benchmark Tool
Correct answer: Prime Vendor Program (PVP)
The Prime Vendor Program (PVP), managed by Apexus, is the main tool used to access additional discounts and ensure compliance.
Question 2: What is the function of a replenishment model in 340B inventory management?
- Estimate yearly demand
- Reduce staff workload
- Track usage and trigger orders based on actual dispensing (Correct answer)
- Standardize patient co-pays
Correct answer: Track usage and trigger orders based on actual dispensing
Replenishment models track dispensed drugs and reorder to maintain accurate 340B inventory levels without diversion.
Question 3: Why is physical inventory reconciliation important in 340B programs?
- To satisfy state board regulations
- To detect over-prescribing by physicians
- To confirm 340B compliance by aligning data and inventory (Correct answer)
- To calculate billing margins
Correct answer: To confirm 340B compliance by aligning data and inventory
It ensures that purchases, dispensing records, and inventory align, preventing diversion and duplicate discounts.
Question 4: Which of the following is an acceptable inventory model for 340B compliance?
- Blended inventory without tracking
- First-in, first-out inventory
- Virtual inventory model with proper tracking (Correct answer)
- Cash-only inventory system
Correct answer: Virtual inventory model with proper tracking
A virtual inventory model separates 340B and non-340B inventory at the data level, maintaining compliance while allowing efficient operations.
Question 5: What documentation is essential for proving 340B purchases?
- Physician credentials
- Medication expiration logs
- Invoices and purchase orders for 340B drugs (Correct answer)
- Patient health surveys
Correct answer: Invoices and purchase orders for 340B drugs
Invoices and purchase orders are critical documentation for tracking and verifying 340B transactions.
Question 6: Why should covered entities avoid stockpiling 340B drugs?
- It increases warehouse maintenance costs
- It delays Medicaid rebates
- It may lead to noncompliance with 340B program requirements (Correct answer)
- It reduces access to contract pharmacies
Correct answer: It may lead to noncompliance with 340B program requirements
Stockpiling can result in program noncompliance by violating intent of usage rules and distorting purchasing data.
Question 7: Which entity negotiates sub-ceiling prices for 340B participants?
- FDA
- HRSA
- Apexus (Correct answer)
- CDC
Correct answer: Apexus
Apexus, as the 340B Prime Vendor, negotiates lower prices below the 340B ceiling price to provide additional savings.
Question 8: What helps prevent diversion in 340B inventory management?
- Unified dispensing with no tracking
- Overordering during price drops
- Maintaining distinct and auditable inventory records (Correct answer)
- Relying on wholesaler tracking alone
Correct answer: Maintaining distinct and auditable inventory records
Clearly defining and maintaining separate tracking of 340B and non-340B drugs is key to avoiding diversion.
Question 9: Which practice supports compliance in purchasing under 340B?
- Purchasing in bulk for all departments
- Ordering only based on lowest price
- Restricting purchases to eligible outpatient services (Correct answer)
- Submitting orders via fax only
Correct answer: Restricting purchases to eligible outpatient services
Limiting purchases to eligible outpatient settings ensures purchases align with patient eligibility requirements.
What is the primary tool for covered entities to purchase 340B drugs at discounted prices?