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SHIP grantee hospitals may be eligible for the 340B Drug Pricing Program

Thanks to a change in the cap on the Medicare Disproportionate Share (DSH) adjustment for rural hospitals, SHIP grantee hospitals may now be eligible for the 340B Drug Pricing Program.

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (P.L. 108-173) increased the DSH cap for small urban and rural hospitals to 12 percent. That change has opened the door to the 340B program, which provides substantial savings on outpatient drug purchases for participating entities. For more information and to find out if your facility qualifies for this benefit read “Eligibility” below and visit HRSA's Healthcare Systems Bureau, Office of Pharmacy Affairs Web site.

The Program
Section 340B of the Public Health Service Act was enacted through passage of the 1992 Veterans Health Care Act. The 340B program sometimes referred to as PHS pricing or 602 pricing, enables certain Federal facilities to obtain dramatic discounts on outpatient drugs. In order to participate in the Medicaid program pharmaceutical manufacturers are required to participate in 340B. Consequently, drugs purchased through this program have extremely discounted prices. On average, 340B drugs cost 20 to 40 percent of the Average Wholesale Price (AWP). Drugs purchased through the 340B program can only be used by the covered entities' patients, and covered entities cannot "double-bill" by including those drugs in the state Medicaid rebate program.

Eligibility
A variety of entities including Federally Qualified Health Centers (FQHCs), Urban Indian Health Centers, Family Planning Clinics and others are eligible to participate in 340B. In addition, disproportionate share hospitals (as defined in section 1886(d)(1)(B)) of the SSA that meet the following eligibility criteria are also eligible to participate:

(i) be owned or operated by a unit of State or local government, is a public or private non-profit corporation which is formally granted governmental powers by a unit of State or local government, or is a private non-profit hospital which has a contract with a State or local government to provide health care services to low income individuals who are not entitled to benefits under title XVIII of the Social Security Act or eligible for assistance under the State plan under this title;
(ii) for the most recent cost reporting period that ended before the calendar quarter involved had a disproportionate share adjustment percentage (as determined under section 1886(d)(5)(F) of the Social Security Act) greater than 11.75 percent or was described in section 1886(d)(5)(F)(i)(II) of such Act; and
(iii) does not obtain covered outpatient drugs through a group purchasing organization or other group purchasing arrangement.
Although Critical Access Hospitals are safety net providers, they are not eligible to participate in the 340B Program because they receive cost-based reimbursement and do not have a disproportionate share adjustment percentage.

Applying
Applying to participate in the 340B program is relatively straightforward. If your hospital meets the eligibility criteria above, visit the website of HRSA's Office of Pharmacy Affairs (OPA) for additional program information and to download the required enrollment forms from the Disproportionate Share Hospital & 340B link. Entities are admitted to the 340B program on a quarterly basis so please note the quarterly deadlines for submission of registration forms. Written confirmation will be forwarded upon completion of the registration process.
Please direct questions about the 340B program to:

Office of Pharmacy Affairs
Toll Free: 1-800-628-6297
Local: (301) 594-4353

Pharmacy Services Support Center (PSSC)
PSSC Call Center:

Toll Free: 1-(800) 628-6297
Local: (202) 429-7518

  


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