The Association of American Medical Colleges (AAMC) and the American Hospital Association (AHA) filed separate comment letters this week targeting the 340B fight — AAMC on CMS’s Medicare Drug Price Negotiation Program rule, AHA on Sen. Bill Cassidy’s 340B Drug Pricing Integrity and Affordability for Patients Act discussion draft. Here are five provisions the two groups want changed.
- Maximum Fair Price effectuation. In an Aug. 14 letter, the AAMC asked CMS to require drug manufacturers to apply the Maximum Fair Price prospectively rather than retrospectively, arguing retrospective effectuation has created operational problems and given manufacturers a rationale to push 340B toward rebate models.
- Manufacturer choice of pricing method. The AHA’s Aug. 25 letter opposed draft language letting manufacturers choose among upfront discounts, retrospective rebates or a claims data repository, warning a rebate model would create cash-flow strain for hospitals and give manufacturers more control over required discounts.
- Contract pharmacy cap. The AHA asked lawmakers to drop the draft’s five-pharmacy cap and geographic restrictions on contract pharmacy arrangements, citing data that 80% of rural hospitals rely on contract pharmacies to deliver 340B savings.
- Child site eligibility standards. The AHA called for revising proposed eligibility tests tied to Medicare cost reports, provider-based status and shortage-area designation, arguing the standards could disqualify outpatient clinics serving medically vulnerable patients.
- The “340B margin” reporting metric. The AHA pushed back on a proposed public metric calculating the gap between payments for 340B drugs and acquisition costs minus hospitals’ costs to run their 340B programs, saying it would overstate hospitals’ benefit from the program and distort its value.
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