August 2, 2011—Health care providers enrolled in the 340B drug discount program will appeal in person next week to a National Council for Prescription Drug Programs (NCPDP) work group to change its standards so that pharmacy benefits managers (PBMs) and private payers cannot use them to lower reimbursement for 340B retail drugs.
Groups representing hospitals, hemophilia treatment centers, and family planning clinics say their proposed revisions would help ensure that covered entities can keep and use their 340B savings to benefit their patients, as Congress intended. They also say that without the changes, they would be required to disclose 340B prices to private payers in violation of federal law and guidance from the Health Resources and Services Administration.
“Although our organizations have a long history of supporting increased transparency in the U.S. pharmaceutical market, we are concerned that NCPDP’s efforts to increase transparency of 340B transactions in the area of third-party adjudication will have the unintended effect of reducing reimbursement to safety-net providers which, in turn, will undermine the purpose of the 340B program,” they wrote to NCPDP last month in advance of next week’s meeting in Atlanta. “Due to these concerns, we cannot support implementation of 340B identification standards at this time. However, we would support moving forward with such standards after measures are established to protect against the benefit of the 340B program being inappropriately shifted to private insurers and PBMs.”
The letter was signed by the National Association of Children’s Hospitals and Related Institutions, the Hemophilia Alliance, the National Family Planning and Reproductive Health Association, and Safety Net Hospitals for Pharmaceutical Access.
The groups asked NCPDP to remove point-of-sale and retrospective identification of 340B claims from the organization’s Telecommunication Standard until there are safeguards to protect them from decreased reimbursement. They also asked NCPDP to limit the use of values requiring submission of 340B prices to Medicaid fee-for-service programs only.