November 2017 – 340B Insider

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


    CMS UPDATE: Final Regulation Cuts Nearly 30 Percent in Medicare Part B Drug Payments to 340B Hospitals

    As you are aware, Centers for Medicare & Medicaid Services (CMS) published on 11/1/17, a final Outpatient Prospective Payment System (OPPS) regulation that cuts Medicare Part B drug reimbursement to 340B hospitals for separately payable drugs by nearly 30 percent, from average sales price (ASP) plus 6% to ASP minus 22.5 %.

    Download the Final rule from CMS.

    Important Facts:

    • The reduction is effective January 1, 2018.
    • The payment reduction applies to hospitals enrolled in 340B as disproportionate share (DSH) hospitals and rural referral centers (RRC).
    • Does NOT apply to critical access hospitals (which are not paid under the OPPS), rural sole community hospitals, children’s hospitals, and PPS-exempt cancer hospitals.
    • The change applies to most, but not all, 340B drugs. Only vaccines and drugs that are on transitional pass-through payment status (assigned status indicator “G”) will be excluded from the Medicare Part B payment reduction. CMS did say that it is open to reconsidering additional exemptions in future years based on further data or information.
    • Coding updates: CMS is requiring impacted hospitals and facilities to add the modifier “JG” on the same claim line as the HCPCS code to identify any drug purchased through the 340B program. For rural sole community hospitals, children’s hospitals, OPPS-exempt cancer hospitals, or any other hospital exempt from the payment reduction, they must also use a modifier “TB” on the claim line to identify any drugs purchased through the 340B program. This change is also effective January 1, 2018.
    • CMS may revisit these policies for CY 2019 and is especially interested in exploring policies addressing the needs of safety net hospitals, which play a critical role in serving the most vulnerable populations.

    Read more from CMS.

    RxStrategies’ viewpoint:

    The payment reductions are specific to 340B Split Bill related reimbursement levels (without any current impact on Contract Pharmacy activity eligibility or reimbursement levels).
    RxStrategies agrees and supports 340B Health’s position and other leading hospital groups in challenging the CMS ruling. Read a statement from 340B Health President and CEO Ted Slafsky.

    RxStrategies is working with our existing clients impacted by the OPPS regulation to help prepare operationally to be ready to support these new regulations.
    We will share any additional information related to the OPPS regulation as it becomes available.

    Please contact us at 877-464-3879 with specific questions.



    Register to attend the 340B Health Webinar: Medicare Part B Drug Payment Cuts to 340B Hospitals; 11/14/17 – 3:00 – 4:00PM ET. Register here by 11/10.


    Health Resources & Services Administration


    Hospitals That Already Began or Completed Recertification MUST Go Through the Process Again.

    The Health Resources and Services Administration (HRSA) Office of Pharmacy Affairs (OPA) announced, due to technical difficulties experienced during hospital recertification, and to ensure the accuracy and integrity of hospital data, there is a new 340B recertification process.

    Key Information:

    • Recertification must be completed by 12/6/17.
    • ALL hospitals will have to complete recertification regardless of whether you have already completed recertification, or if you were in the process of completing recertification.
    • You should have received an email that officially opened the recertification process and provided the extended timeframes to complete the process.
    • Authorizing officials (AOs) and primary contacts (PCs) must set up accounts to complete recertification.
    • Hospitals must annually recertify their eligibility to remain in the 340B program and continue purchasing covered outpatient drugs at discounted 340B prices.
    • Hospitals that fail to recertify their eligibility will be terminated from the program.

    RxStrategies’ response: Our 340B program experts are ready to help provide any form of support to your Covered Entity through this new registration process. Suggested next steps include:

    • Confirm your designated AO for your CE and child-site(s). This must be the same contact.
    • Identify your parent PC and child-site PC(s), they may be different.
    • Contact your RxStrategies’ Account Manager to raise any/all questions related to this new process. RxStrategies will work directly with APEXUS/HRSA to clarify and support.



    Join Us at ASHP 2017 Midyear Conference

    RxStrategies is pleased to be Host Level Sponsor for the ASHP 2017 Midyear Conference, being held in Orlando, December 3-7.
    Our team will be connecting with pharmacy leaders to gain insight and discuss the latest 340B Program developments.

    If you are attending, stop by booth #309 or contact us to schedule an appointment.




    Thank you for opportunity to support and serve your organization.

    We wish you and your family a wonderful and bountiful Thanksgiving.

    With Gratitude,

    The RxStrategies Team






    Join the RxStrategies team at the following upcoming conferences:

    ASHP Midyear 2017, Clinical Meeting & Expo
    Dec. 3 – 7 | Orlando, Florida
    Learn more.

    2018 340B Coalition Winter Conference
    Feb. 21 – 23 | San Diego, California
    Learn more.