340B Insight

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340B Insight provides members and supporters of 340B Health with timely updates and discussions about the 340B drug pricing program. The podcast helps listeners stay current with and learn more about 340B to help them serve their patients and communities and remain compliant. We publish new episodes twice a month, with news reports and in-depth interviews with leading health care practitioners, policy and legal experts, public policymakers, and our expert staff.

  1. 7월 27일

    Why Your Hospital Might Consider Opening a Retail Pharmacy

    With hospitals facing increasing drug company restrictions on access to 340B savings and other challenges, some might be considering opening their own retail pharmacies to serve their patients. We speak with Sherstin Willyerd, director of pharmacy operations at Montgomery County Memorial Hospital in Iowa, to learn about how her hospital went this route and what others want to consider before doing the same.  Buying Existing Pharmacies Can Be a Solution  Willyerd said her hospital was able to purchase two independent pharmacies whose owners were retiring, providing an existing dispensing infrastructure and patient base from which to start. While the hospital still has some contract pharmacy partnerships, the in-house locations can serve patients and generate 340B savings that are less prone to drugmaker restrictions. A Retail Pharmacy Can Give Better Insight into Patient Struggles Operating a retail pharmacy allowed Willyerd’s hospital to see more clearly which patients were struggling with prescription drug costs and medication adherence and to provide more assistance to them. She noted that capturing more 340B savings makes it easier to pass along more discounts to patients who otherwise would not be able to afford their drugs. An Independent Insurance Plan Means Even More Assistance Montgomery County Memorial Hospital also partnered with a pharmacy benefit manager (PBM) to create a primary and secondary prescription drug insurance plan that it offers to certain patients with low incomes and hospital employees. Willyerd noted that this plan can mean hundreds of dollars in savings per month for uninsured patients and those whose coverage comes with high cost sharing. Resources: HRSA Releases 340B Purchase Data for 2025

  2. 7월 13일

    What Illinois 340B Advocates Did To Succeed on 340B Protections

    After years of lobbying and advocacy work by 340B covered entities, the Illinois state legislature approved major 340B legislation earlier this year that protects 340B contract pharmacy access and prohibits drugmaker claims on data demands. Thomas Yu, system director of ambulatory pharmacy services at Sinai Chicago, discusses the campaign that made this legislative victory possible and what covered entities in other states can learn from this success. Joint Events Showed Unity Among Safety-Net Providers Yu says two “340B Saves Lives” days of action in Chicago helped drive support for the legislative effort. Under the leadership of an association representing community health centers, the events brought together covered entities, patients, lawmakers, and others to show a united front on the issue of protecting 340B. The Story of 340B Resonated With Lawmakers, Not Numbers Alone Yu reiterates that statistics and data can be helpful in making the case for 340B but that the story of 340B is what can swing votes. Focusing on community impact and how covered entities use their savings to benefit patients was much more effective at imparting the importance of legislation to protect access to those savings. Illinois Legislation Was a Compromise  The legislation package in Illinois contains 340B reporting requirements for covered entities in the state. Yu argues that this compromise was necessary as the contract pharmacy and claims data provisions would have been a “nonstarter” without that addition. However, because the numbers go to the state for a one-time report and because drugmakers also must report data, he says the overall legislative package still makes for a big win for covered entities and patients in the state. Resources Illinois Legislature Delivers Contract Pharmacy Victory for 340B HospitalsProposed Medicare Pay Cut for 340B Drugs Would Be Much Deeper Than 2018-2022 Reductions

  3. 6월 29일

    How Courts Are Shaping the Future of 340B

    With scores of pending lawsuits involving drugmaker and covered entity challenges of how federal and state governments regulate 340B, the courts have become an important arena in the national 340B debate. 340B Health’s Vice President of Legal and Policy Amanda Nagrotsky unpacks some of the cases and what they might mean for 340B’s future. Courts Wrestle With Issues of Federal and State Authority Drug companies have filed about 80 lawsuits challenging state contract pharmacy protection laws. Nagrotsky says drugmakers are arguing these state laws conflict with federal oversight, but most courts so far have ruled that contract pharmacy protection laws fall within a state’s ability to regulate drug distribution and delivery. A recent decision from a federal judge in Mississippi was a major win for covered entities because it completely dismissed a drugmaker’s challenge to the state’s law rather than just ruling on whether to pause enforcement of the law.  AbbVie Challenges 340B Patient Definition Drugmaker AbbVie is suing the Health Resources & Services Administration (HRSA) directly, arguing that the definition of whom the agency considers a 340B-eligible patient is too broad. AbbVie’s own, narrower patient definition would require drug companies to discount far fewer drugs and thus would limit hospital access to 340B savings significantly. The government is asking the court to dismiss the lawsuit on procedural grounds, and 340B Health along with two member hospitals are asking the court to allow them to intervene as defendants and provide additional arguments for why it should throw out the case. Uncertainty Remains Despite GPO, Child Site Rulings Federal district court decisions found that HRSA failed to explain why it adopted a 2013 policy barring certain 340B hospitals’ use of group purchasing organizations (GPOs) to make initial purchases for their virtual inventory systems and a 1994 policy establishing registration prerequisites for new 340B hospital outpatient facilities. Although the government opted against appealing the ruling striking down the GPO policy, the underlying prohibition remains in effect, leaving hospitals in limbo as to how HRSA will interpret the law. The government has appealed the child site ruling, and a final decision on that case will have a major impact on how quickly hospitals can use 340B drugs at new child sites.

  4. 5월 26일

    How To Calculate How the IRA Will Affect 340B in 2027

    Hospitals already have felt some of the effects of the Inflation Reduction Act on 340B savings, but with the IRA set to expand to more drugs in 2027, hospitals also are starting to project how it might affect their bottom lines next year. 340B Vice President of Pharmacy Services and Education Steven Miller joins us to explain how hospitals can be making those projections now. The IRA Will Expand to Another 15 Drugs Next year, an additional 15 drugs will be subject to Medicare price caps under Medicare Part D on top of the 10 drugs that saw caps this year. Steve says this will cut into 340B savings and overall margins even more — with some 340B discounts possibly dropping to their statutory minimums. These reductions also will translate to commercial and cash-pay dispenses, changing the overall financial outlook for hospitals. Hospitals Cannot Rely on Current 340B Savings Levels for 2027 Steve says the 2027 changes are key for future budgeting. If hospitals do not adjust how they are budgeting for 340B drugs subject to Medicare price caps, they are likely to be short on their budget projections. He strongly recommends 340B teams have important conversations with finance teams now about how the IRA will affect their hospital or health system next year. Hospitals Can Be Planning Now For the rest of 2026, Steve recommends hospitals monitor list pricing and 340B ceiling pricing regularly and to increase monitoring of purchases overall, given how drugmaker pricing behavior affects future 340B prices and savings. As the IRA continues to broaden over the next several years, including to Medicare Part B dispenses, he also recommends hospitals consider securing funding or support from other areas for any 340B-funded services that might see negative IRA impacts. Resources: Prepare Your Leadership for 340B Changes From 2027 Medicare Drug Price Caps

  5. 5월 11일

    How To Navigate a Drug Company’s Good-Faith Inquiry

    Drug companies often initiate good-faith inquiries of covered entities (CEs) to learn more about certain purchase patterns or volumes, but how should hospitals navigate these requests? Bibi Wishart, director of pharmacy at Atrium Health, describes what she’s learned being on the receiving end of these inquiries. Why Do Good-Faith Inquiries Happen? Bibi says the recent rise in good-faith inquiries is tied in part to drug companies gaining access to more varied data sources and expressing a goal of ensuring the information they collect is in line with what they are expecting. She says a variety of different factors could trigger this type of inquiry, including new providers purchasing certain drugs, concerns about duplicate discounts, or confusion around whether a drug is being used in an inpatient or outpatient setting. Hospitals are very complicated, so responding to an inquiry often can be more about educating drug companies about how hospitals dispense drugs. How Should a Hospital Respond? If her hospital receives a communication from a drug company through its authorized official and primary contact, Bibi says she prefers to respond within one or two business days just to confirm she has received the inquiry. She says that while it may take several days or weeks to respond with the requested data, that initial response establishes a cooperative tone and ultimately might prevent escalation to a formal audit process. That also gives the 340B team time to pull in the correct departments and hospital data to provide a full response. Ways To Prevent the Need for Inquiries Due to the sheer complexity of dispensing drugs — including reconciling data feeds from third-party administrators, vendors, and electronic medical records — regular internal audits are one of the best ways to identify discrepancies before drugmakers launch inquiries about them. Bibi recommends using internal auditing to catch these issues and having clear procedures in place for how to resolve any potential errors.

  6. 4월 13일

    The Rebate Debate and Other “Fast and Furious” 340B Developments

    340B lately has had a news cycle that seems to change by the hour, and 340B Health President and CEO Maureen Testoni joins us to break down some of the biggest news happening in Washington, D.C., and in courthouses around the country. HRSA Seeks Feedback on Reviving Rebates  After courts halted the rebate pilot that was set to go into effect in January, Maureen notes that the Health Resources & Services Administration is seeking more information on a possible revival of its rebate plans. Hospitals are responding with their objections, as are lawmakers on Capitol Hill. Nearly 100 members of the House of Representatives wrote a letter to the committee in charge of funding HRSA urging it to block federal spending for any HRSA rebate model. Huge Rulings on the GPO Prohibition, Child Site Registration The past several months have seen big 340B rulings from federal courts. One decision vacated HRSA guidance that had blocked certain 340B hospitals’ use of GPOs for their initial drug inventory, finding that HRSA failed to properly explain the reasons for that restriction. The other decision found that HRSA similarly failed to explain a rationale for restricting 340B eligibility for child sites for up to 23 months after the sites come online. Maureen notes that HRSA could appeal the rulings or seek to issue new guidance. Federal Government Weighs in on State Contract Pharmacy Lawsuits For the first time, the federal government has filed briefs in support of drug companies in several lawsuits over state contract pharmacy protection laws. In these briefs, Maureen says the government effectively is telling judges it does not believe states have the right to protect contract pharmacy because federal 340B law preempts such actions. With the federal government weighing in on the matter and a recent split among appeals courts over the issue of preemption, it is possible this issue might be appealed at some point to the U.S. Supreme Court. Resources Use Our Letter Template Today To Oppose Development of a New 340B Rebate ProgramNearly 100 Members of Congress Urge Funding Block for 340B Rebate ModelPlease Help Advocate for Enforcement Actions Against Drugmakers’ In-House Claims Data DemandsFederal Court Vacates HRSA’s 2013 GPO Prohibition PolicyFederal Court Decides HRSA Child Site Eligibility Restrictions Are UnlawfulFederal Government Backs Drug Companies in Litigation Over State Contract Pharmacy LawsAppeals Court Blocks West Virginia 340B Contract Pharmacy Law, Creating Potential Split with Other Circuits340B Health Impact Profile Guidebook and Template

  7. 3월 30일

    How To Improve 340B Inventory Management

    One of the most important responsibilities hospitals have in maintaining 340B compliance is effective and accurate inventory management, but how do hospitals juggle data from multiple systems and minimize discrepancies? Christina Carrizales Cortez, associate director of 340B compliance for UI Health in Chicago, outlines some of the common inventory issues she encounters and explains how her team works to prevent and fix discrepancies. 340B Discrepancies Can Come From a Variety of Sources Christina says that because 340B compliance relies on monitoring and analyzing a multitude of data feeds, inventory discrepancies can come in multiple forms. A wholesaler might lack an electronic interface — meaning items must be manually entered and verified by the hospital team. Accounts might not have up-to-date inventory locations and addresses. Test claims, a practice by which pharmacies ascertain the cost to a patient of certain drugs, can lead to discrepancies if they do not end up dispensing those drugs. Understanding Systems Can Be Key to Reducing Discrepancies Christina says that the terminology and quirks of 340B can introduce confusion. One remedy, she says, is to explain 340B better so non-340B staff can understand it. Breaking down the basics of 340B and explaining its intricacies can go a long way in rooting out common pain points. Other Tips for Reducing Discrepancies Christina finds that comprehensive monthly reviews are an excellent way to find mismatches, as are instituting different checkpoints in the review process. Analyzing data points such as timestamps can reveal patterns for hospitals. Mapping out all vendors and routinely auditing split-billing software can help ensure better compliance as well. Resources Federal Court Decides HRSA Child Site Eligibility Restrictions Are Unlawful

  8. 3월 9일

    Lessons From a Pro in Advocating Effectively for 340B

    As state legislatures shape up to be the primary battlegrounds for 340B in 2026, Memorial Healthcare Associate Vice President of Advocacy and Government Relations Ben Frederick joins us to share what he’s learned about advocating for 340B. Early Involvement “Crucial” as Focus Shifts to States Ben notes that as states started becoming the primary venues for debating 340B legislation, lobbying efforts from both hospitals and pharmaceutical companies began increasing. This snowballed into deeper conversations — and misleading narratives — about the intent of 340B. Those conversations underscored the importance of hospitals lobbying early and frequently with key stakeholders to help set the record straight about 340B. 340B as Key to Hospital Resiliency For Ben, one of the biggest points he comes back to is the importance of the flexibility of 340B savings. With safety-net hospitals operating on thin margins, the ability to access 340B and the freedom to use savings where the community needs them most is essential not just for serving patients but in many cases for keeping the lights on in the first place. Know Your “Why” for Supporting 340B When illustrating the importance of 340B, Ben told us about his “why” for 340B: When his father received a terminal cancer diagnosis, it was 340B funding that enabled his local hospital to invest in the top-notch cancer treatments and palliative care he received. That is how his father was able to receive his treatments five minutes from home instead of 45 minutes away. Those resources afforded Ben’s family a “dignity of local access” that 340B can provide patients in hospitals nationwide. Resources HRSA Considering Broader 340B Rebate Model Than Withdrawn Pilot340B Health Impact Profile Guidebook and Template

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340B Insight provides members and supporters of 340B Health with timely updates and discussions about the 340B drug pricing program. The podcast helps listeners stay current with and learn more about 340B to help them serve their patients and communities and remain compliant. We publish new episodes twice a month, with news reports and in-depth interviews with leading health care practitioners, policy and legal experts, public policymakers, and our expert staff.

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    340B Health
  • 방송 연도
    2020년 - 2026년
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