Events & News
We are so happy to get back out on the road! Although some conferences and events remain virtual, more and more are opening up and we are running back with open arms! We hope to see you soon!
Please see below for our events and news
Johnson & Johnson Alert Customers Regarding Updates to 340B Delivery Limitations
On Feb. 15, Johnson & Johnson informed all end customers of updates to their policy regarding Bill To/Ship To orders. The updated policy will take effect March 7, 2023, impacting Bill To/Ship To orders involving contract pharmacies used by non-grantee 340B Covered Entities, subject to exceptions within the announcement document.
Johnson & Johnson is poised to become the first drug maker to place a condition on 340B sales and deliveries to covered entity in-house pharmacies. Until now, drug manufacturer conditions and the lawsuits they have spawned have focused on 340B sales and deliveries to contract pharmacies. This announcement came 15 days after the U.S. Third Circuit Court of Appeals ruled that “Congress never said that drug makers must deliver discounted Section 340B drugs to an unlimited number of contract pharmacies.”
To read the full announcement, click here.
Rite Aid Is Now Allowing ESP Claim Submission
In response to drug manufacturers policies that require Covered Entities to submit claims to 340B ESP related to their existing 340B Pharmacy Services Agreement, Rite Aid now grants limited data to be shared to 340B ESP and limited to active contract pharmacy arrangements provided that the Covered Entity adheres to the parameters and guidelines set.
Rite Aid agreed that the following data fields can be shared to 340B ESP provided that the elements asterisked below are appropriately de-identified pursuant to 45 CFR § 164.514 prior to submission or usage by 340B ESP. The required de-identified Data Fields are Date of Service, Date Prescribed, and RX Number.
APPROVED DATA FIELDS:
- Contracted Entity ID
- Date of Service* -De-Identified
- Date Prescribed* -De-Identified
- Prescriber ID (NPI or DEA)
- Prescriber ID Qualifier (“01” for NPI or “12” for DEA)
- Rx Number* -De-Identified
- Service Provider ID (Pharmacy NPI or DEA)
- Service Provider ID (“01” for NPI or “12” for DEA)
- Wholesaler Invoice Number
- Pharmacy NPI
OptumRx Requiring Consent to Share 340B Claims Data
According to a May 26 email to entities, pharmacy care services company OptumRx is requiring 340B covered entities to get consent before sharing OptumRx contract pharmacy claims data with drug manufacturers to satisfy manufacturers’ conditions on 340B pricing. The federal government told eight of the 16 companies who put conditions on 340B pricing that their policies are illegal. While seven drug manufacturers are suing to have the government’s decisions struck down, covered entities spending more and earning less due to the companies’ denials of 340B pricing are weighing whether to give in and supply the claims data. 340B provider groups told the government that providing claims data to a drug manufacturer or drug manufacturer third-party vendor will compromise patient privacy and puts their members at legal risk. To read more click here.
AstraZeneca Pricing Issues
In early April, 340Basics noticed a significant increase in issues with AstraZeneca drug pricing, seeing that AstraZeneca pushed a bad file to wholesalers to update their systems regarding pricing restrictions for our accounts. This caused accounts with exceptions to be blocked and sent to us at retail pricing instead of 340B pricing. The file was likely sent from AstraZeneca to wholesalers at the end of March/beginning of April. Price files for our accounts were incorrect as of 4/2, but wholesalers are indicating that the pricing is reflecting correctly on their end, likely meaning AstraZeneca corrected the errors with an updated file sent to wholesalers after 4/2. 340Basics has not seen all accounts updated with new files to confirm and are working to request updates on affected accounts ASAP. If you have an account affected by this and wish to ensure new files are received, please contact us here: https://340basics.com/contact-us/
Gilead Announces 340B Contract Pharmacy Restrictions
Gilead recently imposed conditions on 340B pricing on its branded hepatitis C treatments when covered entities use contract pharmacies. The policy, which applies to hospital and grantee entities, comes in the same week that entities became aware of an apparent change in Gilead’s HIV drug reimbursement practices, giving contract pharmacies second thoughts on whether they want to continue to partner with 340B providers. Hospitals and grantees reported receiving a March 15 letter by email stating that starting May 2, 340B covered entities must provide claims level data for Gilead’s branded hepatitis C products to remain eligible for bill to/ship to orders for multiple contract pharmacies.
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