Crowe Horwath is a public accounting, consulting, and technology firm with offices across the globe. They are an industry leader in internal auditing, and the company is full of experts in process development. They have leveraged their experience over the years to create a fine-tuned auditing process that allows them to efficiently achieve high-quality results and massive savings for their clients.
Crowe specializes in auditing compliance for 340B, a drug discount program that allows hospitals to repurchase outpatient drugs at significantly reduced cost. Participating in the 340B program provides hospitals with substantial savings opportunities and allows them to deliver care to underserved populations, but proper implementation and ongoing compliance monitoring are complex and involved processes.
Demand for 340B audits is high because a hastily implemented or poorly managed program can result in having to pay back the savings acquired from prescriptions that were incorrectly identified as 340B eligible. Crowe provides hospitals with detailed insight into individual prescriptions that are being incorrectly categorized and uses this information to help identify and resolve overall issues with program implementation and process.
Crowe’s 340B auditing service consists of four primary steps:
1. Data Collection
2. Understand Eligibility Definitions
3. Test Eligibility Definitions
4. Identify Root Cause and Steps to Address
Steps 1-3 are custom to each hospital and require a lot of effort from highly skilled Crowe resources with expertise in both 340B and data analytics. Because this process can be so difficult and time consuming, there is a bottleneck where the analysts need to test eligibility definitions. This slows down the auditing process and limits the number of hospitals Crowe can work with.
Additionally, Crowe conducts these audits manually with customized processes each time. This is slow and expensive for the hospitals, and ignores the large amount of overlap between audit
Enliven partnered with Crowe to create software that would automate the auditing process. This would help Crowe auditors keep up with demand, enhance the quality of auditing service, and reduce the resources needed to complete an audit. Our team has worked with Crowe in the past, so they were excited to bring our team in during the beginning stages of this project to discuss their vision for the project, and where to start.
It’s important to choose the correct part of the four-step process to automate, by balancing what hospital users would want with what Crowe internally needs (that being, to reduce resource commitment and transition to self-service).
We want to automate as much of the process as possible to increase the speed of a 340B audit; however, the program must be flexible enough to accommodate the many variables that can come up. The program should empower the auditor and ultimately, allow hospitals to conduct their own audits.
High-level Monitoring and Analysis
In addition to creating a platform with which Crowe can conduct an audit, the software should present findings and analytics in a digestible way so executives can get a high-level snapshot of their hospital’s situation. Additionally, monitoring should be available to support a hospital as they make progress over time.
The End Product
Customizable Test Logic
In the foundational launch of the 340B software, we have introduced a combination of base logic and a series of settings to customize any auditing project. The test logic is able to be manually updated, but in a way that’s simple enough that auditors don’t have to be exposed to test logic to set it up. Even with a large number of variables, we cover almost any situation.
Variations that used to require manual set-up by data experts can now be managed by someone who just needs to understand a hospital’s set-up. This reduces the time and expertise required by an auditor, and allows Crowe to use their highly-trained analysts in other places.
Outstanding Summary Data with Trending Analysis
One of the features to receive the most positive feedback is the fact that our application tests all data available. Administrators don’t see a sample set, but rather a comprehensive review of all the input data. Our review goes one step past reporting, so in addition to the review, administrators see the results in a comprehensive list of potential issues. This allows them to conduct detailed investigation of individual exceptions, identify the root causes of these exceptions, and address broader issues with program implementation (to minimize their risk and maximize their savings).
When auditors or hospital professionals log into 340B, the application opens up to a dashboard that provides a high-level view of analytics. In addition to summaries, the dashboard records a hospital’s progress to give results on what is trending. This gives evidence that they’re addressing the right problem in the right way, provides a full history of improvement, and updates continually.
After an audit of a hospital is finished, the hospital receives tons of supporting data which allows them to research individual exceptions with tools like filtering, searching, managing default views, and easy sharing. Summary data allows us to prioritize research, like we see here:
Pharmacy 3 is having an issue, and because we have this data sectioned out we can understand and address the issue quickly. An outstanding UI/UX further supports investigation, allowing management to quickly understand and react to these reports.
We partnered with Crowe Horewath to develop an application that would provide major efficiency gains for them and the hospitals they work with. With 340B, hospitals gain a new way to dig deep into the details of how their 340B drug discount program is running, and have continuous monitoring going forward. Crowe can conduct audits faster, more extensively, and with less expensive resources. This tool has long-lasting value and will ultimately allow them to teach hospitals to conduct their own internal audit.
We completed the application foundation, and are starting to engage with hospitals. Our pilot hospitals are providing valuable feedback so we can determine the most significant next features.
We are working on new features for the application, including one that will provide insight into the financial impacts of 340B participation. Within reports, individual exceptions each have a financial impact - noting that a hospital is either missing an opportunity to categorize a prescription as 340B (which represents a lost savings opportunity), or they’re incorrectly categorizing a prescription as 340B (which represents a compliance risk). Those are values that we can capture and present as well, giving yet another level of insight into impact and prioritization of the exceptions being identified. We’re excited about moving forward with Crowe Horwath LLP to create a service that doesn’t exist in the industry right now!