Through Vizient’s 340B Program Assessment, Gwinnett Health System was able to immediately lower its $40 million annual drug spend by $1.5 million—and expects greater savings to come.


Good leaders know when they need to get guidance from experts. Carol Danielson, RN, FACHE, CNE, senior vice president and chief nursing executive at Gwinnett Health System, wanted to ensure that the organization’s 340B program was as strong as it could be. “As the chief nurse executive, pharmacy isn’t my area of expertise—but it’s an area that I’m always concerned about. And because 340B is so incredibly complex, I believed a consultant was the best way to go to strengthen our program.”

Director of Pharmacy Michael Naughton, PharmD, was in complete agreement. “We needed outside expertise to assist in improving our program. We had very few internal resources to leverage. If you really want to be successful, you can’t just have this be another additional duty for your employees,” he pointed out.

Gwinnett’s pharmacy department was also at what Naughton referred to as a “critical juncture” with regard to the department’s functioning. “We hadn’t done an evaluation from a consultant’s point of view, and we needed to know how we compared to our peers,” he said.


Gwinnett’s leaders chose to take advantage of Vizient’s experience and expertise in evaluating the hospital’s 340B program. Vizient’s 340B Program Assessment includes an end-to-end program evaluation, in-person interviews with team members to help build rapport, and mock Health Resources and Services Administration (HRSA) audits. Vizient also provides a final report with detailed recommendations and specific action plans.

Overall, the Vizient 340B Program Assessment helps organizations fine tune program performance, minimize associated risks, and make sure the program will pass an HRSA audit without issues. Gwinnett’s team knew this was the kind of thorough, expert review they needed.

“There are many processes you must put in place for the 340B program regarding how you purchase drugs, track them through the health system, and prescribe them for patients,” said Danielson. “It requires following the dose through the entire process and many pharmacies aren’t equipped to do that. Vizient proved to be an expert—and that’s not an easy feat to achieve because there are so many gray areas within the regulations.”

The Gwinnett team was so impressed with Vizient’s assessment, in fact, that they asked Vizient to extend the engagement to include implementation of the performance improvement plan.
Vizient gave Gwinnett a head start on its improvement efforts by categorizing the projects identified during the assessment by degree of risk. Vizient then provided project management throughout the implementation, working with every area covered by the project scope, including managing interactions and follow-ups.

Vizient’s implementation work with Gwinnett involved instituting policies and procedures, including procedures to align the system’s purchasing, IT, and split-billing databases; establishing an audit structure; training staff; and identifying opportunities to maximize financial opportunity.

Part way through the 340B program engagement, its success to date prompted Danielson and Naughton to ask that Vizient conduct an operational assessment of Gwinnett’s pharmacy department at the same time. The assessment looked at pharmacy staff utilization, skill mix, and leadership structure, and used Vizient’s high-quality comparative data to benchmark Gwinnett against its peers. “Vizient has a great database upon which to draw and help us benchmark the pharmacy’s performance against similar health care organizations,” noted Naughton.

Two questions remained on Naughton’s mind as Gwinnett’s outpatient areas adapted to the changing health care environment: “Did we have the right amount of staff? Did we have them where we need them?” Explaining the rationale for asking Vizient to conduct the departmental evaluation, Naughton said, “Those questions already existed. 340B was the driver for enlisting Vizient’s help and we were able to merge the two projects.” After the assessment was complete, Vizient provided recommendations for areas that could be consolidated, or have hours reduced, to enable more pharmacists to work in areas where they were needed most.

Gwinnett’s Vizient consultant, Bonnie Senst, helped calm staff worries by being clear about her purpose from the beginning. “It’s always a challenge for employees to get past their fears when they hear the word consultant,” said Naughton, “but Bonnie did a great job of articulating her purpose and scope during the introductions. She puts people at ease, and that’s a great strength.”


“Vizient’s assistance enabled us to immediately remove $1.5 million from our $40 million annual drug spend, and that’s minimal compared to what I believe the potential savings could be,” reported Danielson. The health system can now reinvest those savings in additional services for patients, thereby improving its quality of care.

Equally important, Vizient’s 340B assessment and project management work resulted in a strong, comprehensive, compliant program that Gwinnett is able to proactively manage—and sustain. “Vizient integrated the 340B regulations, Apexus (340B prime vendor) resources, best practices, and Gwinnett’s operations to optimize their 340B program,” said Senst.

Although no one likes to hear the word audit, Danielson reported that the organization is now ready for one if it occurs. “Vizient advised us on the actions we needed to take to manage a compliant program and pass an HRSA audit in the event we are audited, including writing policies, convening an oversight committee, improving the drug databases feeding data to our accumulator software, and establishing meaningful audits.”

The departmental assessment also produced answers that will help position the system for a better future. “Vizient produced a fabulous operational assessment—a snapshot of how our organization looked and the challenges resulting from how we were structured—that has helped me convince our leaders that our pharmacy is not overstaffed and, if anything, we could use additional staffing. We received a lot of value from this assessment in terms of deliverables,” said Danielson, who relied on Vizient’s presentation to make the case to Gwinnett’s leadership to place pharmacists in the emergency department.

Naughton reported that throughout the engagement with Vizient, he experienced a rapport unlike any he had ever had with a consultant. “The trust level was much higher with Vizient. [Bonnie] made it very functional from the standpoint of interfacing, following up, and coordinating with different areas—all while I continued running the pharmacy department. Her expertise made that possible.”

And although the 340B and pharmacy assessments are complete, the system’s work with Vizient likely is not. “Once we feel like we’re done with our internal operational changes, I can see us asking Vizient to help us with some other things—likely in our next fiscal year,” said Danielson. “I know there are more benefits out there for us in the future and Vizient is the one to help us pin them down.

We received a lot of value from the Vizient assessments. Vizient’s 340B and pharmacy operational expertise helped us to make significant 340B program improvements and have the staffing complement to be successful in our operations.
Carol Danielson, RN, FACHENE Sr Vice President and Chief Nursing Executive