Public Comments | 340B Matters
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***NOTE: The below information is derived from public comments filed on in response to HRSA’s proposed mega-guidance. Use here does not imply any affiliation with 340B Matters or endorsement from the entities themselves.  

“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)
“The 340B program is vital to the mission of Kootenai Health. Any change in the 340B program could potentially mean significant positive or negative changes to our community benefit and our ability to stretch scarce federal resources as far as possible, reaching more eligible patients and providing more comprehensive services, which is core to the 340B program… Kootenai Health has participated in the 340B program since 2011. Over this time period Kootenai Health has been able to increase its Community Benefit (Free and Discounted Care for Those in Need, Community Health Improvement Services and Community Programs and Services) from $5.5 million in 2010 to $18.1 million in 2014. Kootenai Health would have never of been able to do this without the 340B program.” – Kootenai Health Public Comment (Coeur d’Alene, Idaho)
“Franklin Hospital is committed to ensuring that our most vulnerable populations- including indigent, uninsured and underinsured patients- receive high quality health care, including having access to needed medications. 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)
“The mission of `{`Bon Secours Health System`}` is to bring compassion to health care and be good help to those in need, especially those who are poor and dying. In fiscal year 2014, BSHSI provided $301.4 million in direct community benefit with 57% of that in the communities our covered entities serve. The 340B program allows us to further extend the benefits of our programs and offer a higher level of charity care services. In conjunction with the 340B program, our covered entities provide innovative and lifesaving programs such as mobile clinics, bedside prescription programs, and medication vouchers.” – Bon Secours Health System Public Comment (Marriottsville, Maryland)
“People living within Tampa are 21.4% below the US Census poverty level guidelines. As a safety-net hospital, `{`Tampa General Hospital`}` provides extensive care through our emergency department to unfunded and underfunded patients who cannot access primary care expeditiously…over one-third of TGH's total discharges are either uninsured or underinsured. The TGH total community benefit in fiscal year 2013 was $116,364,460 and includes charity care, subsidized health services, financial and in-kind contributions to local charities; health professions education; research and community health improvement.”
– Tampa General Health Public Comment (Tampa, Florida)
“During our fiscal year ended April 30, 2015, we furnished more than 36,000 encounters for chemotherapy services. Our primary care clinics furnished over 82,000 medical visits with uninsured or Medicaid patients during that same period. 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)
“Erlanger is among the state’s leaders in providing charitable benefits to the communities that it serves. Erlanger provided over $86 million to the community and region in the form of uncompensated care and free services in fiscal year 2014. In fiscal year 2015, it provided an additional $87 million. The 340B Program is essential to enable Erlanger to continue serving our low-income and vulnerable population. The savings derived from Erlanger’s participation in 340B enable us to provide critical and life-saving services to our community and to stretch scarce federal resources to further our patient care mission, as intended by the Congress. HRSA’s proposed Mega-Guidance would eliminate the vast majority of the savings to Erlanger and impede our ability to continue serving our patients to the same extent we are serving them today. Our savings would be reduced by eighty eight percent (88%), primarily due to the loss of 340B pricing in our infusion centers and in our physician clinics, along with the elimination of discharge prescriptions. A reduction of this magnitude in our savings will directly impede our ability to serve patients.” – Erlanger Health System Public Comment (Chattanooga, Tennessee)
“Last year we purchased approximately $2.5 million worth of 340B drugs for employee prescriptions. Our costs would increase 65%, more than $4 million, if we were unable to make use of 340B drugs for these prescriptions and are required to use either Wholesale Acquisition Cost (WAC) or community pharmacies. The shortfall in the benefits program and the resulting impact on the hospital's net margin may lead to budgetary cuts in indigent care programs provided by the hospital.” – Navicent Health Public Comment (Macon, Georgia)
“As part of our commitment to the community, our total community benefit initiative in 2014 invested millions of dollars into the community: $117.3M was invested in traditional charity care; Medicaid and other means-tested programs stood at $139M, and $10M in unbilled community services… The 340B Program is essential to enable BayCare’s 340B eligible hospitals to continue to serve our low-income and vulnerable populations. HRSA’s proposed Mega-Guidance would eliminate half of the 340B benefits to our CEs, therefore increasing our costs and impeding our ability to continue serving our patients.” – BayCare Health System Public Comment (Clearwater, Florida)
“The most significant pharmaceutical assistance we provide our patients is through our enrollment in the 340B program, which we joined in 2003. We have found ways to pass the savings we receive from the program directly to the patient buying the medication. Through the first seven months of calendar 2015, we passed some $780,000 of savings through the program directly to the patient through development of a ``sliding-scale`` program. Many of these 340B savings went to patients who desperately needed the medication to recover from illness or injury and would never have been able to afford the prescribed drugs.” – New Hanover Regional Medical Center (Wilmington, North Carolina)
“The Section 340B program is critically important to our hospitals, which together, function as the largest safety net provider in our community. Rochester, New York is the 5th poorest ci t y among the nation's top 75 metropolitan areas. Nearly one third of its residents live below the federal poverty level. The discounts and savings `{`our two Disproportionate Share Hospitals`}` receive through the Section 340B program have a direct and demonstrable impact upon the hospitals' ability to meet the health care needs of medically needy patients. Shortly after `{`we`}` enrolled in Section 340B in 2003, the hospitals developed well-publicized financial assistance policies that offer generous self-pay discounts to medically needy individuals… `{`We`}` expect to extend approximately $70 million in discounts to uninsured and underinsured patients in 2015 as a result of these programs. The hospitals also use their Section 340B savings to provide free and discounted medications to medically needy patients, particularly those being discharged following an inpatient hospital stay.” – University of Rochester Medical Center Public Comment (Rochester, New York)
“340B is an essential part of the delicate balance of revenues and expenses that allows HFHS to continue to carry the burden of charity care as a not-for-profit health care system… In 2014, the System provided $325 million in uncompensated care to Detroit-area residents…The estimated savings from 340B in our system - $89 million for 2014 – represents a significant fraction of the cost of charity care and other forms of uncompensated care. Any restriction on 340B would have the effect of reducing our ability to provide charity care; charity care has always been, and will continue to be, a core part of the mission of HFHS.” – Henry Ford Health System Public Comment (Detroit, Michigan)

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