DUBLIN, Ohio, Feb. 4, 2016 /PRNewswire/ -- For hospitals
considering enrollment in the Federal 340B Drug Pricing Program, or
those already participating in the program, the Health Resources
and Services Administration's (HRSA) recent Omnibus Guidance, often
referred to as the 'Mega-Guidance,' could have significant impact
on plans and operations, once the final guidance is published in
September 2016.
In a new blog post on the Cardinal Health thought leadership
site, Essential Insights, Daniel Neal, director of 340B Product and
Service Marketing, summarizes the Mega-Guidance's key proposed
changes, including a new requirement that has patients meet six
conditions – an increase from the current three – for eligibility
to receive medication purchased at 340B prices, as well as a
revised criteria for qualifying sites of care.
As a result of the Mega-Guidance, Neal discusses four ways
hospitals can prepare for the potential impact of the proposed
ruling, including:
- Assess the potential impact of the proposed program
changes. For example, if you already have a strong network of
contract pharmacies, or if you are considering creating one,
carefully review the current projected prescription volume that
would flow through those channels. If prescriptions filled at those
sites could no longer qualify for 340B pricing, what would be the
financial impact?
- Develop contingency plans for each risk area. For
example, if your facility would be significantly impacted by the
rule's proposed changes to 'managed Medicaid' prescriptions,
determine what kind of agreements would need to be developed for
those prescriptions to continue to qualify for 340B pricing.
Consider meeting with your state Medicaid office to get insight on
how best to develop your related contingency plan.
- Conduct an audit of your 340B program – not just measuring
against current standards, but also by the proposed
Mega-Guidance. Now more than ever, 340B covered entities
recognize the significance of maintaining a compliant program.
Regardless of which facets of the proposed rule get
implemented, the ability to navigate complex and evolving
guidelines is key to protecting critically important program
savings.
- Make your voice heard. HRSA's official comment period
for this proposed Mega-Guidance is over, but it's important for all
stakeholders to share their perspectives on these proposed changes.
Sharing your perspective with your congressional representatives,
other elected officials and advocacy groups is critical to ensuring
HRSA fully understands the potential impact the proposed changes
may have on the way covered entities provide patient care.
"As with any worthwhile initiative – especially in today's
evolving healthcare landscape – creating a strong 340B program for
your hospital is best viewed not as a destination, but as a
journey," says Neal. "When managed correctly, including appropriate
oversight, planning and preparation, this program can continue to
be a cornerstone of an eligible hospital's ability to improve
access to care and sustain their community mission."
To learn more about the Mega-Guidance changes and Neal's
insight, read his full blog post on Cardinal Health's Essential
Insights.
About Cardinal Health
Headquartered in
Dublin, Ohio, Cardinal Health,
Inc. (NYSE: CAH) is a $103
billion health care services company that improves the
cost-effectiveness of health care. Cardinal Health
helps pharmacies, hospitals, ambulatory surgery
centers, clinical laboratories and physician
offices focus on patient care while reducing costs, enhancing
efficiency and improving quality. Cardinal Health is an essential
link in the health care supply chain, providing
pharmaceuticals and medical products and services to
more than 100,000 locations each day and is also the
industry-leading direct-to-home medical supplies distributor.
The company is a leading manufacturer of medical and surgical
products, including gloves, surgical apparel and fluid management
products. In addition, the company operates the nation's
largest network of radiopharmacies that dispense products
to aid in the early diagnosis and treatment of disease. Ranked #26
on the Fortune 500, Cardinal Health employs more than 36,000
people worldwide. More information about the company may be
found at www.cardinalhealth.com and @CardinalHealth
on Twitter.
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SOURCE Cardinal Health