340B March Madness (Duplicate Discounts)

I haven't come up with a Covered Entity v. HRSA Audit bracket yet; sorry to disappoint. The second quarter of 2020 (and the next HRSA 340B registration period) is only weeks away!  The 340B Coalition Winter Conference is behind us, and your post-conference fervor may be dying down due to the myriad of competing priorities all covered entities must balance.  

As of 2/25/2020, HRSA has completed 170 Program Integrity Audits for 340B Covered Entities in Fiscal Year 2019.  Here are some interesting statistics:

• Of the twenty-four (24) Community Health Centers* audited, 18 (75%) had adverse findings by OPA.
  • 17 of the 18 CHCs with findings cited Duplicate Discounts among the deficiencies noted (94%).
• Of the four (4) Ryan White** grantees audited, 1 had adverse findings.
• Of the three (3) STD grantees audited, 1 had adverse findings.

It may be tempting to wait until the July conference to get your next round of 340B education. If you do one thing for your 340B program between now and July, check on your organization's Medicaid Exclusion File status, your policy to avoid Duplicate Discounts, and your state's guidance for billing both Managed Care and Fee for Service Medicaid.

Medicaid rules change frequently and Medicaid's communication of those changes, in my experience, may leave you with more questions than answers.

Email communication with state Medicaid is best; save those correspondence documents!  You may need them in the event of a real HRSA audit.

Check with your in-house pharmacy (and medical stock), plus contract pharmacies to ensure compliance with your organization's carve in/out policy, including Managed Care Medicaid.

Check out your state's current requirements from Apexus: 

www.340bpvp.com/resource-center/medicaid

​*Covered entities with the prefix "CH" or "CHC"
​**Covered entities with the prefix "RWII" or "HV"