For hospitals considering enrollment in the federal 340B Drug Pricing Program, or for those already participating, the Health Resources Service Administration's recent Omnibus Guidance could have significant impacts on plans and operations.
On Cardinal Health's thought leadership blog, the company's director of 340B product and service marketing proposed four ways hospitals can better prepare for the potential impact of the proposed changes.
1. Calculate the financial impact. Hospitals should carefully review their current projected prescription volume that flows through contract pharmacies and consider the financial impact should prescriptions filled at those sites no longer qualify for 340B pricing.
2. Develop contingency plans for each risk area. If a provider will be significantly impacted by program changes, the hospital should determine what agreements will need to be developed to continue to qualify for 340B pricing.
3. Conduct an audit of your 340B program. It is more important than ever for providers to assess the compliancy of their drug programs as hospitals and pharmacies continue to navigate complex and evolving rule changes.
4. Make your voice heard. Although the Health Resources and Services Administration's official comment period has concluded, it is still important for stakeholders to share their perspectives and opinions with congressional representatives, advocacy groups and elected officials to ensure HRSA fully understands the impacts of the proposed program changes.