Medicaid Fee for Service can now claim Medicaid rebates for managed care claims. Does this mean that you have to bill managed care claims at acquisition for 340B products?
A: The answer depends upon the billing agreement and is not determined by section 340B. Covered entities are required to ensure that they do not bill drugs purchased under 340B if those drugs are subject to a rebate claim by the State Medicaid Agency. So long as that requirement is met, 340B does not specify the precise reimbursement methodology. On March 15, 2000 HRSA published its current guidelines on billing Medicaid. HRSA recommends that covered entities refer to their respective Medicaid State agency drug reimbursement guidelines for applicable billing limits. ftp://ftp.hrsa.gov/bphc/pdf/opa/FR03152000.htm
We recommend that you check any agreements that you have with manufacturers, the 340B Prime Vendor Program, or others to determine if they contain restrictions regarding price sharing.
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