Critical Pharmacy Program Strategies and Innovations

Pharmacy programs represent one of the highest-ROI opportunities available to tribal health organizations, and one of the most consistently underutilized. This piece, published in Tribal Gaming & Hospitality Magazine, outlines the programs and structures that change the financial equation for tribal pharmacy operations: 340B drug pricing, IHS/BIA partnership structures, 105(l) lease arrangements, and grant programs that fund program infrastructure.

The 340B Drug Pricing Program is the most consequential piece for most tribal programs. Eligible tribal health organizations can acquire outpatient drugs at significant discounts and generate margin on pharmacy dispensing, in some cases enough to meaningfully offset clinic operating costs. But 340B eligibility is tied to organizational structure, and many tribal programs that should qualify have not completed the enrollment process or are not operating in a way that maximizes the benefit.

105(l) leases, the mechanism by which the federal government funds the lease or construction of IHS facilities operated by tribes, intersect with pharmacy in a specific way: a pharmacy operating within a 105(l) structure can qualify for reimbursement rates and program access that a standalone clinic cannot. The article walks through how these program interactions work and what organizational decisions drive pharmacy program performance.

Grants round out the picture. While grant funding is less reliable than structural program access, several federal streams, including IHS, HRSA, and HHS grant programs, specifically target tribal pharmacy infrastructure. Face Rock's approach is to use grant funding to stand up program infrastructure while structural programs like 340B and 105(l) provide the sustainable revenue base.