Twenty four large health systems with hospitals in the 340B program yesterday sent U.S. Health and Human Services (HHS) Secretary Xavier Becerra eight recommendations “to stabilize this program for the long-term” that he could implement without involving Congress.
The coalition, which began meeting last year and focuses in particular on 340B disproportionate share hospitals’ concerns, asked Becerra in an April 19 letter to:
- eliminate the nearly 30 percent reduction in Medicare Part B reimbursement for hospitals’ physician-administered, 340B-purchased drugs
- require drug manufacturers to stop restricting 340B pricing on drugs shipped to and dispensed by contract pharmacies
- continue implementing the 340B administrative dispute resolution process “to allow covered entities the ability to appeal judgements against them”
- make results of manufacturer 340B program compliance audits and any issues of non-compliance publicly accessible
- create a repository of all Medicaid fee-for-service programs’ and Medicaid managed care plans’ prescription benefit information, to help covered entities avoid duplicate discounts, and to let state Medicaid agencies and entities enter into 340B shared savings arrangements
- review how drug rebates give pharmacy benefit managers (PBMs) an incentive “to siphon off the benefits of the 340B program for themselves
- investigate how PBMs have created new ways “to distribute high-cost infusion drugs as a way to circumvent the 340B pricing requirements, and ensure that infusion drugs “remain in the normal supply chain and not be allowed to be distributed directly to the patient”
- halt any movement by manufacturers to turn the 340B program into a rebate model.
“The 340B program was created in 1992 to ‘permit covered entities to stretch scarce Federal resources as far as possible, reaching more eligible patients and providing more comprehensive services,’” the health systems wrote. “Our hospitals do just that by integrating our savings back into our communities through services and programs within and outside our physical walls in both rural and urban areas.”
“As hospitals systems across the country with facilities enrolled as 340B entities, we look forward to working with you to maintain the sustainability of the program for entities such as ourselves,” they said.
The letter was signed by:
- Aultman Health Foundation (Ohio)
- Baptist Health (Kentucky and Indiana)
- CentraCare (Minnesota)
- Centura Health (Colorado and Kansas)
- Hackensack Meridian Health (New Jersey)
- Henry Ford Health System (Michigan)
- Legacy Health (Oregon and Washington)
- MaineHealth (Maine and New Hampshire)
- Methodist Le Bonheur Healthcare (Tennessee and Mississippi)
- Monument Health (South Dakota)
- Mountain Health Network (West Virginia)
- Munson Healthcare (Michigan)
- Nebraska Medicine (Nebraska)
- OSF Health Care (Illinois and Michigan)
- Parkview Health (Indiana and Ohio)
- Piedmont Healthcare (Georgia)
- Presbyterian Healthcare Services (New Mexico)
- ProMedica (Ohio and Michigan)
- The Queen’s Health Systems (Hawaii)
- Sanford Health (South Dakota)
- SCL Health (Colorado, Montana, and Kansas)
- St. Luke’s Health System (Idaho)
- University of Utah Health (Utah)
- University of Vermont Health Network (Vermont)