The 340B Drug Discount Program has been a public policy success story from the beginning. It has been exceptionally successful in expanding access to health care in underserved areas, both rural and urban. Even the program’s worst critics must acknowledge the incredible benefits 340B has provided for more than 30 years.
Despite the tremendous effectiveness of the program, it’s not perfect. We have documented how pharmaceutical companies consistently abuse 340B to pad their excessive profits. There are also steps that hospitals can take to enhance the long-term sustainability of the program.
340B Matters believes that 340B hospitals should unite behind a set of principles that will guide future efforts to improve the program. Here are some that we offer for consideration by all 340B stakeholders:
Stability
1. Define contract pharmacy and ensure its availability to safety-net hospitals and clinics.
2. Clarify that the 340B benefit is intended for healthcare providers, their patients and communities — not third parties.
Equity
3. Prohibit manufacturers from imposing special data requirements or other restrictions on contract pharmacies and healthcare providers that limit access or prevent discounts at the point of purchase.
4. Ensure that the definition of a patient, for the purposes of 340B eligibility, includes modalities for virtual care.
5. Prohibit discriminatory actions by Pharmacy Benefit Managers or insurers against healthcare providers and their contract pharmacy network.
6. Prohibit hidden direct and indirect remuneration (DIR) fees on 340B claims.
7. Require that 340B eligibility follows a manufacturer’s product, regardless of packaging or manufacturer acquisition/merger.
Transparency
8. Develop a mechanism by which healthcare providers can share information on 340B program benefits to the Health Resources and Services Administration on an annual basis.
9. Prevent duplicate discounts in Medicaid through a government-managed clearinghouse.
10. Create and maintain a central location for Medicaid Managed Care BIN/PCN/Group identification codes to avoid duplicate discounts.
