Thank you for the information this will be real good for the Company down road.
Covered entities rely upon the 340B program to effectively serve the neediest patients in their community.
• Loss of 340B pricing at contract pharmacies resulted in lack of patient access to lifesaving medications and reduced covered entity revenue potential.
$ $ • Other than establishing the June 1 deadline for drug companies’ compliance plans, HRSA has not yet released more information on how or when affected covered entities might receive the millions of dollars lost through denied 340B drug pricing program discounts.
$ $ • To encourage 340B Program Integrity, a policy for the covered entity to file a notice to HRSA of overpayment for covered entities contracted pharmacy arrangements should be enacted. Report manufacturer overcharges or a lack of 340B pricing, to HRSA, using the 340B Ceiling Price Unavailable/Incorrect 340B Ceiling Price Notification template.
• To access financial damages, take the labeler code within the NDC (first 5 digits of the 11-digit NDC
number identifies the manufacturer) for those 6 manufacturers and tally up the number of
prescription transactions that went to a contract pharmacy and were prevented from dispensing under the 340B discount program.
• To develop analytic proof of financial damages, work with the drug wholesale distributor to calculate the financial loss for each transaction (WAC Price-340B Price= amount owed to covered entity) and total the sum for the time period of 10/1/2020 to present.
• Be patient, as clarity for the next steps will take some time. These six drug companies have fought every effort to gain adherence with the law since the start of this issue. Vizient will continue to
monitor and advise.
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