NRHA calls on members to protect 340B Program

By: Diane Calmus and Brock Slabach | 8/28/17

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Since 1992, NRHA has enthusiastically supported the 340B Drug Discount Program. This program requires drug manufacturers to provide outpatient medications at a discounted price to eligible entities. NRHA added its voice in support of expanding this discount program to all Critical Access Hospitals (CAH) through the Affordable Care Act (ACA) passed in 2010. As a result, patients in rural communities all over the US have access to affordable medications through participating rural hospitals and other eligible entities such as Federally Qualified Health Centers (FQHC).

On July 13, 2017, CMS released its Outpatient Prospective Payment System (OPPS) Notice of Proposed Rule Making (NPRM). In this NPRM, CMS proposed significant changes to the 340B program for hospitals paid under the OPPS system (important note, this rule does NOT apply to CAHs or FQHCs). The proposed policy would pay eligible 340B hospitals 77.5 percent of the average sales price (ASP) for most separately payable Part B drugs. CMS currently pays for these drugs at 106 percent of the ASP. NRHA is opposed to this change as it will threaten the sustainability of the rural safety net. The 340B program will be featured at NRHAs upcoming RHC/CAH meeting in Kansas City, MO Sept. 26-29, 2017. NRHA Partner 340B Health will conduct a post-conference workshop on Friday, Sept. 29.

The proposed change in the 340B program is especially troubling in light of the rural hospital closure crisis. Since 2010, eighty rural hospitals have closed. Not surprisingly, 65% of these closed hospitals are PPS, the group of hospitals directly threatened by this very proposal.  At the same time, a third of all remaining rural hospitals are vulnerable to closure according to Chartis iVantage Health Analytics. Many of these vulnerable hospitals participate in the 340B program.

Finally, rural Americans are older, sicker, and poorer than their urban counterparts. They are more likely to have chronic diseases, such as diabetes, that make access to regular medical care and medications essential to avoiding debilitating, costly, and painful complications. To ensure these vulnerable populations can access necessary pharmaceuticals, it is important for Congress and HRSA to strike an appropriate balance when overseeing the administration of this vital program.

NRHA needs you to help us tell Congress and the Trump Administration just how important 340B is to the rural safety net. NOW is not the time for these changes. Write a comment letter to CMS opposing this rule change by September 11. Reach out to your member of Congress and let them know how important the 340B program is to the patients of your community. Share your story, including pictures, with NRHA so we can make your voice…louder.