29 Oct Ways to Improve 340B Drug Discount Program

By 340B Matters

Senator Lamar Alexander (R-Tenn.) and Rep. Greg Walden (R-Ore.) have asked stakeholders in the 340B Drug Discount Program to submit ideas on how it can be improved. It’s a request that both pharmaceutical manufacturers and safety-net healthcare providers should take seriously.

With a few updates, the program would run more smoothly for all involved and ensure that 340B continues to fulfill its mission to help safety-net health providers stretch scarce resources to reach more eligible patients and provide comprehensive services. Here are eight key areas for modernization:

1. 1. 1. Require states to maintain an active role in the avoidance of duplicate discounts. This includes research and resolution of 340B claims that are inadvertently invoiced for a Medicaid rebate.  The Centers for Medicaid Services should require each state to publish their 340B policies and findings and to work in good faith with manufacturers to resolve problem claims.
      2. Require state Medicaid Managed Care Organizations to assign a unique identifier to each plan and publish an up-to-date listing of the plans. This change would help health providers identify Medicaid patients and avoid invoicing claims thereby creating a duplicate discount.
      3. Require HRSA to audit pharmaceutical manufacturers at the same rate annually as it does 340B hospitals. Historically, the agency has spent far more time investigating providers and let drug companies off the hook.
      4. Expand 340B to Substance Abuse and Mental Health Services Administration programs to reduce opioid addiction and behavioral health challenges exacerbated by the pandemic.
      5. Expand 340B access to patients seen in University and College campus clinics.
      6. Formalize the HRSA dispute resolution process to allow for all parties to present grievances, including the latest tactics deployed by manufacturers to circumvent the 340B law.
      7. Stop manufacturers and pharmacy benefit managers from discriminating against 340B covered entities and their agents on the basis of non-Medicaid rebates.
      8. Exclude 340B claims from Direct and Indirect Remuneration fees. These are claw backs charged by pharmacy benefit managers to 340B hospitals and clinics.

The 340B program is almost 30 years old. American healthcare has changed a great deal during that time. It is smart to consider improvements that will make 340B work better for both providers and drug makers.

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