Maureen Testoni’s Outlook for 340B In 2023

02/06/23 • 26 min

Several 340B developments have occurred in the first weeks of 2023, with many more expected to come this year. In this episode, we speak with 340B Health President and CEO Maureen Testoni about her outlook for 340B. Our discussion includes her analysis of the latest in the 340B contract pharmacy dispute, the 340B advocacy landscape at the federal and state levels, and Medicare issues affecting 340B.

*Editor’s note: We spoke with Maureen prior to Bayer and EMD Serono announcing they will restrict 340B discounts. When these restrictions start in March, at least 21 companies will be limiting 340B discounts, with 14 of these companies conditioning 340B pricing on providers sharing contract pharmacy claims data.*

U.S. Appeals Court Decision on 340B Contract Pharmacies

Litigation continues on drug companies imposing restrictions on 340B pricing to hospitals and other providers when drugs are dispensed through community and specialty pharmacy partners. Maureen discusses a recent U.S. federal appeals court decision and the next steps in the litigation process. She also explains the trends in the drugmakers’ restrictions.

2023 Advocacy Landscape for 340B

Two recent national newspaper stories portrayed 340B in a negative light, but they did not include a complete picture about how 340B works. Maureen discusses what the increased media attention means for 340B advocacy this year and what hospitals should do to advocate for the program. She also shares an overview of 340B legislative activity at the state level.

Medicare Payment Issues for 340B Hospitals

Maureen shares what she will be watching for during the implementation of a new Medicare drug price-setting law. She also explains the status of repayments to 340B hospitals for unlawful Medicare cuts.

340B Administrative Dispute Resolution (ADR) Process

HHS has proposed revisions to the ADR process for resolving disputes between covered entities and drug manufacturers over 340B pricing. Maureen examines how these revisions will clarify the process and further changes that 340B hospitals are requesting.

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources

U.S. Appeals Court Decision on 340B Contract Pharmacies

2023 Advocacy Landscape for 340B

Medicare Payment Issues for 340B Hospitals

340B Administrative Dispute Resolution (ADR) Process

Resources

Previous Episode

Your 340B Questions Answered

We often receive listener questions about 340B issues and developments that affect professionals in the 340B world. In this episode, we open the listener virtual mailbag and answer some of your questions with help from our 340B Health staff experts. Some of the questions we tackle include queries about mitigating 340B contract pharmacy restrictions, understanding 340B patient definition, analyzing current 340B hospital audit trends, and examining Medicare Advantage payment rates for 340B drugs.

Mitigating Contract Pharmacy Restrictions

In response to a listener's question, we discuss ways 340B hospitals can access program savings despite contract pharmacy restrictions. We share data about the amount of 340B savings restored to 340B hospitals when they apply for drug company exceptions.

Hospital 340B Audit Trends

For one listener question, we recap the most recent data on hospital 340B audit results and identify the most common audit finding.

The Impact of Medicare 340B Payment Policy on Medicare Advantage Rates

A listener asks how Medicare Advantage plans are responding to the restoration of full Medicare Part B payment rates for 340B drugs. We discuss what we know and what remains uncertain.

Check out all our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you would like us to cover in this podcast, email us at [email protected].

Resources

Next Episode

Making IT Work With 340B

Health information technology (IT) is intertwined with 340B operations and compliance. So how can hospitals and health systems manage IT while keeping 340B in mind? To find out, we hear from Robert Owens, director of pharmacy enterprise shared services at Atrium Health. Bob is a pharmacy health IT expert, and he shares how the technology intersects with 340B. He also shares insights to ensure strong 340B operations and compliance when undergoing an electronic health records (EHR) system conversion. Before the interview, we provide an update on two more drug companies restricting 340B discounts.

IT's Intersection With 340B Operations

Bob discusses the different types of IT systems providing data that are important for closely monitoring your 340B program, including electronic health records, automated dispensing cabinets, and IV workflow software. He emphasizes the importance of the 340B team members becoming experts on 340B data.

EHR Conversions

Bob explains how EHR system conversions affect 340B operations and compliance. He walks through the steps his team took before and during one of its conversions and points out the potential pitfalls to avoid.

Strategies for Managing NDCs

An EHR conversion means 340B professionals need to be aware of potential NDC challenges that go along with it. Bob shares some questions 340B professionals should ask about charging and administration practices when planning for a change in EHR systems.

Resources