340B PROGRAM: THE DUPLICATE DISCOUNT PROHIBITION AND UPCOMING HRSA GUIDANCE

About the Product
Includes 1 hour Windows Media Video File and PowerPoint presentations for immediate download.

The recent growth of the 340B drug discount program has focused manufacturer attention on the lack of guidance with respect to key areas of the program, such as the prohibition against duplicate discounts. Both the Medicaid Drug Rebate Program and the 340B program relate to “covered outpatient drugs,” and it is therefore possible that a manufacturer sells a unit of product to a covered entity at the significantly discounted 340B ceiling price, only to then receive a rebate invoice from a state Medicaid program for that same unit of product. Both the 340B and Medicaid statutes include provisions intended to protect manufacturers from paying such a “duplicate discount,” with respect to both fee for service (FFS) Medicaid utilization and Medicaid Managed Care (MCO) utilization. However, the Health Resources and Services Administration (HRSA), the federal agency that administers the 340B program, to date has not implemented the duplicate discount prohibition with respect to MCO Medicaid utilization. HRSA is expected to release three significant pieces of regulation this year, which may include guidance addressing the duplicate discount prohibition. This webinar explores the current status of the duplicate discount prohibition, including how HRSA has implemented it with respect to FFS Medicaid utilization, reviews the HRSA guidance expected to be issued this year, and provides suggestions to manufacturers for preparing for the guidance.

Speaker:
Christopher Schott
Associate
Hogan Lovells

Participants that will find this webinar most beneficial will be those involved in pharmaceutical and biotechnology companies. Job titles of attendees that will be most applicable for this session will be:

• Pricing
• Government Affairs
• Managed Markets

Contact:

Brooke Akins | Division Director, Life Science Programs
+1 (312) 224-1693 | bakins@q1productions.com​