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340B Program Management

The 340B Program problem:  Achieving around-the-clock compliance

When asked what’s top of mind for a 340B Drug Pricing program manager , she said, “Knowing if I’m compliant today and if I would survive a HRSA audit without issue if that occurred next week.” The program manager went on to say that “Maintaining and protecting our 340B benefit is extremely important to our profitability.” Maintaining compliance every day and guarding profitability takes a complex balance of foresight and fortitude. Navigating the requirements requires equal parts insight and resources. To help bring that insight, we’re launching a 10-part blog series today that aims to examine not only the challenges to complying with the 340B program but also strategies and tactics for making it easier to do so. Continually complying with the U.S. Health Resources and Services Administration requirements is a linchpin for avoiding the… Read More »The 340B Program problem:  Achieving around-the-clock compliance

Tackling 340B Duplicate Discounts

To say the link between Medicaid and 340B is complicated would be an understatement. By federal law, a covered entity’s 340B program and Medicaid program get discounted drugs for patients with Medicaid, but only one entity can legally receive the discounted drug. This leads to, among other things, administrative stress because covered entities must ensure drug makers aren’t charged two discounts for one drug, otherwise known as duplicate discounts. Everyone from physicians to lawmakers seem to be weighing in on this issue. In December 2022, Pennsylvania distributed a medical assistance bulletin effective Jan. 1, 2023, that seems to indicate the commonwealth will no longer offer Medicaid reimbursements for 340B drugs dispensed by contract pharmacies. Specifically, the bulletin states, “The MA [medical assistance] Program is unable to identify 340B-purchased drugs dispensed by contract pharmacies, therefore, contract… Read More »Tackling 340B Duplicate Discounts