Welcome to the November edition of RxStrategies 340B Insider, a concise communication to provide a quick highlight of updates from RxStrategies’ view.


    RxStrategies works closely with a number of industry thought leaders to keep a pulse on issues potentially impacting the 340B Drug Pricing Program.

    With the 2016 elections now complete, one of RxStrategies’ legal partners, Powers Pyles Sutter & Verville PC, just provided an summary of potential impacts to the Affordable Care Act (ACA).

    Download a summary to read more.



    Medicaid Managed Care Rebate Discussion Continues

    Delaware Medicaid earlier this year proposed requiring 340B Covered Entities to carve out Managed Medicaid. The change was subject to CMS approval of Delaware’s state plan amendment.

    340B Health was pleased to report Delaware covered entities will not have to carve out under the modified version approved by CMS last week. However, if they choose to carve in, they will have to tell the state they are doing so and their decision will apply both to fee for service and managed care Medicaid.

    In the June 2016 OIG report, “State Efforts to Exclude 340B Drugs from Medicaid Managed Care Rebates,” found that to identify 340B drug claims and correctly collect rebates for MCO drugs, most States use methods that identify providers using 340B-purchased drugs. However, provider-level methods may not accurately identify all individual 340B drug claims, creating a risk of duplicate discounts and forgone rebates.

    RxStrategies continues to play a leadership role and support efforts to require additional HRSA clarity surrounding Managed Medicaid rebates. Contact us to learn more.


    Medicaid Resources To Manage Prescription Drug Costs

    The Center for Evidence-based Policy (CEbP) recently released several reports outlining options available to state Medicaid programs to manage prescription drug costs. The reports describe how states currently use 340B to generate drug savings and how they could use 340B to manage drug costs.  Click to read the reports.


    340B Hospitals Ask DOJ for EpiPen Overcharge Investigation

    Hospitals and health systems in the 340B drug discount program have asked the U.S. Justice Department to investigate whether drugmaker Mylan overcharged 340B healthcare providers for EpiPen anaphylaxis rescue auto-injectors.

    In an Oct. 31 letter, 340B Health noted that Mylan’s misclassification of EpiPen as a generic rather than brand-name product resulted in underpayment of Medicaid drug rebate amounts. It asked the department to look into whether Mylan overcharged 340B providers for EpiPen in conjunction with the settlement the department reportedly is negotiating with Mylan over underpaid Medicaid rebates.

    Senate Judiciary Committee Chairman Chuck Grassley (R-Iowa) is holding a Nov. 30 hearing on the reported $465 million settlement. Mylan announced there was settlement in early October but the Justice Department said later there is no executed agreement. It is unclear if the reported settlement addresses 340B overcharges. The November hearing will also explore what the Centers for Medicare & Medicaid is doing to police drug manufacturers’ compliance with Medicaid drug rebate program requirements and to punish wrongdoing.


    New Report: 1:4 Poor/Near-Poor Adults Lack Health Insurance Coverage

    New data from the National Center for Health Statistics show that one out of every four poor and near-poor adults under age 65 still lacking coverage. Despite gains since the Affordable Care Act was passed in 2010, poor Americans continue to be disproportionately uninsured. During the first half of this year, 25.9 percent of working-age poor adults and 23.5 percent of working-age near-poor adults lacked coverage.

    In a May 2016 340B Health survey, 78 percent of hospitals enrolled in the 340B program said they are seeing more patients with insurance but who are still in need of financial assistance. A significant portion (42 percent) said they had seen an increase in the number of self-pay/uninsured patients compared with previous years.



    RxStrategies Solutions Help Stretch Limited Federal Resources 

    RxStrategies is helping retail pharmacies navigate the complexities of 340B program participation by supporting the implementation of fully functional Sliding Fee, Subsidy, Charity Care and Cash plans for their Covered Entity partners. Leveraging RxStrategies’ PBM services, we can set-up plans specifically designed for uninsured patients.

    Our solutions allow your Covered Entity partners stretch limited federal resources, reducing outpatient drug prices for your patients and expanding health services to the patients and communities you serve. Contact us to learn more.


    RxStrategies Client Reviews

    We appreciate receiving comments how RxStrategies has assisted organizations better serve 340B eligible patients. Read below to learn what clients are saying about RxStrategies:

    “Due to RxStrategies’ comprehensive solutions specifically for FQHCs to manage a compliant 340B program, our available discounts from the 340B program tripled in the rural areas where we operate in partnership with contract pharmacies.”

    “Communication throughout the transition process from another TPA was stellar. The RxStrategies team was there for us at a moment’s notice.”

    “The exemplary customer service RxStrategies’ sales department and account managers provide is a key component our strong partnership.”

    Ready to share your experience with RxStrategies? Submit your comments here.



    Join the RxStrategies’ team at the following upcoming conferences:

    ASHP Midyear Clinical Meeting & Exhibition
    Dec. 4 – 8 | Las Vegas
    Learn more.

    340B Winter Coalition Meeting
    Feb. 1 – 3 | San Francisco
    Learn more.

    OACHC 2016 Annual Conference
    Feb. 27 – Mar. 3 | Ohio
    Learn more.

    NACHC Policy and Issues Forum
    Mar. 29 – April 1 | Washington, D.C.
    Learn more.