BREAKING: HRSA Moves Forward on Plan To Allow for Expedited 340B Hospital Clinic Enrollment

Your 340B Report for Saturday June 6, 2020

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BREAKING: HRSA Moves Forward On Plan To Allow for Expedited 340B Hospital Clinic Enrollment

This morning, the Health Resources and Services Administration (HRSA) made it official that hospitals may use 340B drugs at offsite facilities prior to the site being registered on its Medicare cost report, to the extent that patients of the new site are patients of the parent hospital. HRSA is responding to a long-standing complaint from 340B hospitals that have been prevented from accessing discounted pricing at new locations due to the months and sometimes year-long delay when a cost report is filed. Hospitals say the problem has become more acute during the COVID-19 pandemic when HRSA relaxed its enrollment policy but kept its pre-pandemic Medicare cost report requirement. HRSA’s position is reflected in a new 340B program FAQ on its 340B COVID-19 resources webpage.

HRSA also posted a new FAQ on its COVID-19 resources page stating it cannot waive the Medicare disproportionate share adjustment percentage requirement needed for certain hospitals to enroll or maintain eligibility in the 340B program. At the urging of hospital groups, lawmakers are trying to enact legislation that would temporarily relax the statutory DSH percentage threshold requirements.  Some hospitals are concerned that they might lose 340B status due to a change in patient mix during the COVID-19 emergency.

Here are HRSA’s two new 340B program FAQs on its COVID-19 resources page:

In a related development, HRSA’s 340B prime vendor, Apexus, in recent days has modified two 340B program FAQs on hospital registration of 340B offsite facilities.

Apexus posted this modified FAQ on June 4:

Apexus posted this modified FAQ on June 2:

This second Apexus FAQ closely tracks a pre-existing HRSA 340B program FAQ, one that is located apart from HRSA’s COVID-19 FAQs:


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