Kickoff Call: 340B Drug Pricing Program Covered Entity Coalition

16 September 2015 Health Care Law Today Blog

Foley has scheduled a call on Thursday, September 24, 2015 at 8am PST/10am CST/11am EST to convene 340B Program covered entities that may be interested in forming a “coalition” to develop a response to HHS/HRSA’s recently proposed comprehensive 340B Program guidance, beginning with (but not necessarily limited to) the preparation of comments on the guidance. Interested covered entities are invited to attend this free “kickoff” call.

HHS/HRSA’s proposed guidance, if finalized, would have a significant financial and operational impact on participating 340B covered entities.

Some of the key issues raised in the proposed guidance include:

  • The ability to purchase 340B drugs for hospital-based infusion centers where the physician ordering or prescribing the infusion is not employed by/under contract with the hospital
  • New requirement for 340B covered entities to bill for the professional services for individuals receiving 340B drugs
  • New requirement that only patients whose services are billed to payors as outpatient services are eligible for 340B drugs
  • The ability to use 340B drugs when the drugs are reimbursed by Medicaid programs through certain types of bundled payments
  • The ability to use 340B drugs for Medicaid managed care patients, including through contract pharmacies

If you are a 340B covered entity interested in participating in this call, please contact Elizabeth Elson at or the Foley attorney you work with to obtain call-in information.

This blog is made available by Foley & Lardner LLP (“Foley” or “the Firm”) for informational purposes only. It is not meant to convey the Firm’s legal position on behalf of any client, nor is it intended to convey specific legal advice. Any opinions expressed in this article do not necessarily reflect the views of Foley & Lardner LLP, its partners, or its clients. Accordingly, do not act upon this information without seeking counsel from a licensed attorney. This blog is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Communicating with Foley through this website by email, blog post, or otherwise, does not create an attorney-client relationship for any legal matter. Therefore, any communication or material you transmit to Foley through this blog, whether by email, blog post or any other manner, will not be treated as confidential or proprietary. The information on this blog is published “AS IS” and is not guaranteed to be complete, accurate, and or up-to-date. Foley makes no representations or warranties of any kind, express or implied, as to the operation or content of the site. Foley expressly disclaims all other guarantees, warranties, conditions and representations of any kind, either express or implied, whether arising under any statute, law, commercial use or otherwise, including implied warranties of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Foley or any of its partners, officers, employees, agents or affiliates be liable, directly or indirectly, under any theory of law (contract, tort, negligence or otherwise), to you or anyone else, for any claims, losses or damages, direct, indirect special, incidental, punitive or consequential, resulting from or occasioned by the creation, use of or reliance on this site (including information and other content) or any third party websites or the information, resources or material accessed through any such websites. In some jurisdictions, the contents of this blog may be considered Attorney Advertising. If applicable, please note that prior results do not guarantee a similar outcome. Photographs are for dramatization purposes only and may include models. Likenesses do not necessarily imply current client, partnership or employee status.

Related Services