5 Considerations to Adapt to and Prepare for 340B Changes

By Andrew Wilson and Chris Shain

Read time: ~3 minutes

According to the Health Resources and Services Administration (HRSA), which is responsible for administering the 340B program, enrolled hospitals and other covered entities can achieve an average savings of 25 to 50% in pharmaceutical purchases. But, some manufacturers are beginning to scale back their participation in 340B, which could threaten contract pharmacy relationships in the long term. It’s important to thoughtfully assess and understand the potential consequences of these changes. Doing so could help your health system confidently shift focus from concern over the implications of these changes to improving patient care.

In a recent webinar on “Assessing and Addressing the Business Impact of Manufacturer 340B Contract Pharmacy Actions,” experts Andy Wilson and Christopher Shain outlined how contract pharmacies can adjust to the latest 340B manufacturer changes. Together, they offered recommendations to prepare for future actions and potential shifts. Here are five key considerations, as shared in the webinar, to help pharmacies assess impact and achieve more by understanding the financial influence and identifying missed opportunities.

Perform a Self-Audit

Review your individual contract pharmacy accounts to gain an understanding of what your 340B software vendor is doing on behalf of your health system. Look for inconsistencies to ensure you aren’t missing significant opportunities. For example, check to see that your health system’s vendor hasn’t removed products prematurely. Don’t assume that because the software vendor removed the product that it reviewed the pricing. We recommend confirming that none of the products removed from your network are still available at 340B pricing. You could gain a more complete picture of your 340B program by understanding the actions of the manufacturer making sure they line up with the current pricing availability for the drugs and products in question.

Download this list to keep it handy (PDF, 423 KB)

Ensure You’re Meeting the Standards

Make sure you are eligible to access 340B pricing for your contract pharmacy. Was pricing removed? Reach out directly to manufacturer, as they have developed their own forms and questionnaires. If approved, confirm the dates and the direction given to your wholesaler.

Know Your Numbers

Monitor and track 340B cost and revenue changes monthly. To do this, you should have access to robust vendor switch data to track drugs and determine impact. If you don’t, you can access your purchase data through our McKesson tools to help expand your visibility. If you don’t have a manufacturer resource, contact your pharmacy analytics expert, 340B software vendor, or access U.S. Food and Drug Administration (FDA) databases and other available external sources. Additionally, consider having your third-party administrator track eligible prescriptions and accumulations.

Ask the Necessary Questions

The opportunity to gain exceptions is worth exploring. Tell your manufacturer what you’d like to do and ask if this applies to your health system. Manufacturers have had challenges and have become more understanding, looking differently at organizations that use their own retail pharmacies contracted with other members of an integrated delivery network. We’ve seen multiple manufacturers change their policies and practices by which they grant exceptions because of questions from the 340B community. Be sure to keep them coming.

Keep the Lines of Communication Open

If applicable, understand business pressures on your contract pharmacies. There’s a benefit to them, as well. Your contract pharmacy partners have a different perspective and may not necessarily have the understanding you do. As owners of the entity, communicate openly with your partners.

If you have more questions about navigating 340B complexities, contact our team.