Tag Archives: CMS

CMS Proposal to Make One-Time $9 Billion Lump Sum Payment to 340B-Covered Entity Hospitals

By Brenda Maloney Shafer, Richard Davis, Michael French and Madison Hartman on Posted in Compliance, Guidance
The Centers for Medicare & Medicaid Services (“CMS”) recently announced its proposal to make a one-time lump sum payment of roughly $9 billion to 340B-covered entity hospitals that were impacted by the agency’s unlawful reimbursement reductions for 340B drugs billed to Medicare Part B from 2018 to 2022. This proposal comes after the Supreme Court … Continue Reading

CMS Publishes 340B Drug Acquisition Cost Survey: Respond by May 15, 2020

By Brenda Maloney Shafer and Richard Davis on Posted in Covered Entities
On April 24, 2020, the Centers for Medicare and Medicaid Services (CMS) finalized and published a survey intended to capture the actual amounts paid by 340B covered entities (excluding critical access hospitals) for 340B drugs. CMS then intends to use the data collected from the survey to adjust the Medicare Part B reimbursement rate for 340B … Continue Reading

Interesting 340B Takeaways from 2020 OPPS Proposed Rule

By Brenda Maloney Shafer and Richard Davis on Posted in Covered Entities, Legislation
The Centers for Medicare & Medicaid Services (CMS) “respectfully disagreed” with a recent federal district court’s “understanding of the scope of CMS’ adjustment authority” in making cuts to Medicare Part B reimbursement for drugs purchased through the 340B program, saying it plans to continue its 28.5 percent reduction in reimbursement while it pursues an appeal … Continue Reading

The President’s 2020 Budget Keeps 340B Program in the Spotlight

By Brenda Maloney Shafer and Richard Davis on Posted in Covered Entities, Legislation
On March 11, 2019, the President delivered his proposed 2020 budget to Congress. While a President’s budget proposal is the beginning of a lengthy budget process, this proposed budget nonetheless keeps the 340B Program in the national focus and delineates the President’s position on desired 340B Program changes.… Continue Reading

We’re 340Back! Review of Major Developments to the 340B Program

By Brenda Maloney Shafer and Richard Davis on Posted in Audits, Covered Entities, Legislation
It’s been a roller coaster two years for the 340B Program, and we are now back to review some of the major developments and program changes during this time. On the highest level, despite a flurry of proposed legislative action, the 340B Program remains largely unchanged from where it stood prior to 2017. As covered … Continue Reading

How Much Will You Pay for an Inaccurate 340B Ceiling Price?

By Alyce Katayama and Elizabeth Gebarski on Posted in Compliance, Legislation, Manufacturers
Under the authority granted it by the Patient Protection and Affordable Care Act, the Health Resources and Services Administration (HRSA) is moving forward to laying the groundwork for imposing civil monetary penalties on manufacturers that overcharge covered entities under the 340B Program. HRSA has submitted its second Information Collection Request (ICR) regarding calculation and verification … Continue Reading
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