How To Navigate a Drug Company’s Good-Faith Inquiry

Drug companies often initiate good-faith inquiries of covered entities (CEs) to learn more about certain purchase patterns or volumes, but how should hospitals navigate these requests? Bibi Wishart, director of pharmacy at Atrium Health, describes what she’s learned being on the receiving end of these inquiries.Why Do Good-Faith Inquiries Happen?Bibi says the recent rise in good-faith inquiries is tied in part to drug companies gaining access to more varied data sources and expressing a goal of ensuring the information they collect is in line with what they are expecting. She says a variety of different factors could trigger this type of inquiry, including new providers purchasing certain drugs, concerns about duplicate discounts, or confusion around whether a drug is being used in an inpatient or outpatient setting. Hospitals are very complicated, so responding to an inquiry often can be more about educating drug companies about how hospitals dispense drugs.How Should a Hospital Respond?If her hospital receives a communication from a drug company through its authorized official and primary contact, Bibi says she prefers to respond within one or two business days just to confirm she has received the inquiry. She says that while it may take several days or weeks to respond with the requested data, that initial response establishes a cooperative tone and ultimately might prevent escalation to a formal audit process. That also gives the 340B team time to pull in the correct departments and hospital data to provide a full response.Ways To Prevent the Need for InquiriesDue to the sheer complexity of dispensing drugs — including reconciling data feeds from third-party administrators, vendors, and electronic medical records — regular internal audits are one of the best ways to identify discrepancies before drugmakers launch inquiries about them. Bibi recommends using internal auditing to catch these issues and having clear procedures in place for how to resolve any potential errors.