THE VALUED VOICE

CMS Launches Burdensome 340B Survey Despite Hospital Concerns

CMS proceeded with its plan to launch a survey of 340B hospitals starting April 24 and closing on May 15, 2020. This decision came despite strong objections from WHA and other hospital groups who expressed concerns with the regulatory and compliance burden hospitals already face, and the fact that results from the survey would be used to weaken, rather than strengthen, the 340B program. WHA had requested CMS to withdraw the survey even before hospitals were facing new challenges and staffing strains from the COVID-19 response.

The 340B prescription drug program helps hospitals stretch scarce federal resources by requiring drug manufacturers to sell qualifying outpatient drugs at a discount to hospitals and other eligible entities. With rising prescription drug costs increasingly accounting for a larger percent of hospital expenses, the 340B program has provided a welcome respite to rising prescription drug costs that are otherwise outside of a hospital’s control.

According to instructions listed on the CMS website, other than critical access hospitals, all hospitals enrolled in the 340B program in either the last quarter of 2018 or first quarter of 2019 are required to complete the survey by May 15. The survey itself requests acquisition cost data for 340B drugs and is being collected by CMS in response to a federal judge declaring the agency could not legally reduce hospital reimbursements in the 2018 OPPS rule without first obtaining cost acquisition data.

Please contact WHA Director of Federal and State Relations Jon Hoelter with questions.