TIP: When it comes to duplicate discount prevention, don’t assume that all 340B drugs are billed to Medicaid using the same NPI. Routine internal auditing of Medicaid claims and proactive communication with finance/billing can help identify additional NPI numbers that may need to be listed on HRSA’s Medicaid exclusion file.
Many covered entities are not aware of additional NPI numbers that may be used to bill 340B drugs in unique areas of their hospital or clinic. Separately certified dialysis centers, psychiatric units, and rural health clinics often have separate NPI numbers used for billing. Some hospitals may even have a separate NPI number for inpatient billing, which could include 340B drugs administered in an emergency room or observation status prior to the inpatient transition. If 340B drugs are billed to Medicaid in these areas, the NPI number(s) must be listed on the Medicaid exclusion file (MEF) for the applicable clinic sites/registrations to comply with HRSA’s requirements for carve-in entities.
Covered entities should also remember that entity-owned retail pharmacies may have a separate NPI number from the covered entities. If the entity-owned retail pharmacy is billing 340B drugs to Medicaid, the retail NPI must also be listed on the MEF at the parent entity. HRSA publishes the MEF quarterly. Entities may add or remove billing numbers at any time, but the changes will not be effective or appear on the MEF until the following quarter. All changes must be made by the 15th of the month that precedes the new quarter. For example, to appear on the July 1st Medicaid exclusion file, changes must be made by June 15th.
Routine internal auditing of Medicaid bill images from all registered child sites and areas of the covered entities utilizing 340B drugs can help to identify additional NPI numbers in use. Additionally, asking proactive questions and engaging with the Finance and Billing teams is a great way to identify alternate NPIs that should be listed on the Medicaid exclusion file.
Jamila Seibel, Director at Alinea Group, can be reached at firstname.lastname@example.org