The 340B Drug Pricing Program (340B Program) is a federal program that requires drug manufacturers, who participate in the Medicaid Drug Rebate program, to also provide reduced 340B prices on covered outpatient drugs for 340B-covered entities. The purpose of the program is to give covered entities the ability to stretch scarce federal resources as far as possible to reach more eligible patients and provide more comprehensive services. Participation in the 340B program can result in cost saving and revenue generation for health centers. Covered entities receive front-end discounts rather than a rebate later on in the payment process. The National Association of Community Health Centers (NACHC) found that health centers save between 15-60% on their prescription drug costs by using the 340B program, depending on the volume and type of drugs purchased. Savings associated with the program may be used to provide medications at reduced/no cost to eligible patients, expand the list of available medications, serve additional low-income patients, and offer more comprehensive or new health-related services.
340B Brief Assessment Included in OSVs: On October 22, 2014 CPCA received notification via the Primary Health Care Digest that HRSA will include 340B Brief Assessments in OSVs starting October 1, 2014 for health centers in participate in the 340B program. The brief assessment will focus on program compliance with 340B program requirements. The bulk of the site visit will remain on HRSA grant. OSV consultants will assess 340B compliance using several standard questions. 340B/OSV site visits could potentially trigger further investigation by OPA if noncompliance is found. As a result of the visits HRSA is hoping to be able to highlight 340B compliance best practices to assist covered entities.HRSA has stated their goal is: "to maximize the reach of our program integrity efforts, while ensuring transparency for all stakeholders to understand 340B compliance requirements and site visit expectations." I have reached out to Apexus and pulled information from the HRSA website. The following link provides information on site visit preparation, areas of focus for auditors and questions that will be asked.
For 340B technical assistance, please contact Deb Roth, Staff Attorney at firstname.lastname@example.org