WHAT THEY’RE SAYING
“Simply put, if the 340B program were to be compromised, reduced or eliminated our Hospital would not be able to stay open. The program is that important to our existence.” – Washington County Memorial Hospital(Mineral Point, Missouri)
“Thanks to the 340B Program, Franklin Hospital is able to help patients with the high cost of drugs so they are not forced to choose between basic necessities - food, housing, and clothing - and their health because they cannot afford their prescribed medications.” – Franklin Hospital Public Comment (Benton, Illinois)
“Over $37 million of savings from 340B pricing reduced our Medicaid costs and enabled us to continue funding expanded services to uninsured and underinsured patients.” – Memorial Healthcare System Public Comment (Fort Lauderdale, Florida)
“The most significant pharmaceutical assistance we provide our patients is through our enrollment in the 340B program, which we joined in 2003.” – New Hanover Regional Medical Center(Wilmington, North Carolina)
For more examples of public comments, click HERE.
***NOTE: The above statements are derived from public comments filed on regulations.gov in response to HRSA’s proposed mega-guidance. Use here does not imply any affiliation with 340B Matters or endorsement from the entities themselves
Over 1200 Comments Were Submitted in the 340B Drug Pricing Program Docket:
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555 comments were submitted by Hospitals
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387 comments were submitted by anonymous/unknown parties
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144 comments were submitted by “Other”
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84 comments were submitted by Patient Groups
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32 comments were submitted by State Associations
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22 comments were submitted by drug related companies/PhRMA
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21 comments were submitted by National 340B Associations
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10 comments were submitted by 340B Related Companies
Hospitals and Health Centers Strongly Oppose Mega-Guidance Proposals
160 Hospitals And Health Centers Concerned With Loss Of Infusion Services
160 hospitals and health centers are extremely concerned with the potential of losing infusion services. The proposal would exclude individuals receiving infusion or dispensing of a drug as their only health care service from being defined as covered entity’s patient. As a result, a large percentage of vulnerable and low-income patients who receive prescriptions in their local communities and then have to travel to the hospital infusion center will no longer be eligible to receive 340B pricing on those important treatments.
150 Hospitals And Health Centers Concerned With Loss Of Discharge Prescriptions
150 hospitals and health centers expressed major concern over the proposal to exclude inpatient discharge prescriptions from 340B pricing. Hospitals and health centers reported that this requirement would increase patient readmission rates, health care costs for the facility and out-of-pocket costs for the patient to fill his or her prescription. This proposal will cause entities to lose a percentage, if not all, of their 340B savings leading a dramatic reduction of important medical services that treat vulnerable patients.
Provider Employment Proposal Violates The Law
120 hospitals and health centers oppose the proposal that a patient must receive health care services from a provider who is either an employee or an independent contractor of a hospital. The entities assert that a patient receiving health care services in their hospitals or hospital-based facility is, in fact, a patient of their hospital. Entities have cited violations to state laws as a result of this requirement, as many states prohibit hospitals from employing physicians directly. Entities warn that narrowly defining a provider will limit the prescribers within a covered entity, thereby limiting the number of 340B prescriptions that serve vulnerable patients.
150 Hospitals and Health Centers Oppose Exclusion of Medicaid Bundled Drugs
150 entities are concerned with proposals to exclude from 340B drug discount pricing outpatient drugs that are reimbursed as part of a bundled Medicaid payment. Many hospitals and health systems serve a high volume of Medicaid patients and they rely heavily on the discounts received through the 340B program to offset underpayments by Medicaid payers. Some entities reported that it would be impossible to offset these underpayments and continue to provide quality care to low-income patients.
