COVID-19 Response

I would like to begin by thanking our healthcare workers on the front lines in combating the unprecedented COVID-19 pandemic. Much has changed for all of us in the past six weeks! 

Mass layoffs and business closures due to COVID-19 have already left many members of our communities unemployed and without health insurance. Safety net providers may find themselves overwhelmed with caring for an influx of new patients in the coming weeks and months.  Access to affordable healthcare and medications is especially critical during times of health and economic uncertainty. 

Understandably, your organization may not be thinking much about the 340B program right now. However, key changes in healthcare delivery models and the evolution of the current pandemic will likely continue to alter the 340B landscape in unpredictable ways during the months to come. HRSA has already responded to COVID-19 by providing some additional flexibility for 340B program participants. Staying up to date on these changes will allow your organization to maximize the program's benefit and minimize compliance risks during this challenging time.

Here are some tips:

• Contact HRSA to discuss registration of any new sites or contract pharmacy arrangements immediately! In response to the COVID-19 pandemic, HRSA is allowing emergency registrations for certain covered entities outside the traditional time frame of April 1-15. New 340B IDs, Medicaid Exclusion File changes, and contract pharmacy requests are being submitted, evaluated, and approved on a rolling basis at this time. If approved, the waiting period (until July 1) is also waived.
• Telehealth patient encounters, volunteer healthcare providers, and alternate delivery sites: HRSA recommends promptly documenting any healthcare delivery changes (temporary or permanent) in your 340B Policies and Procedures. For purposes of 340B compliance, all patient encounters should be documented in writing and maintained by the covered entity. Best practice is to document the encounter in the EHR (even with limited patient information).
• Safety net healthcare providers are urgently needed on the front lines to combat the COVID-19 illness itself as well as the arrival of new patients presenting due to rapid and widespread economic fallout. Writing prescriptions isn't going to be enough if patients can't afford their medications. Ensure that your 340B program is providing accessible and affordable medication to help vulnerable populations stay healthier.

We must remain vigilant not only in the fight against COVID-19, but to ensure the realization of the 340B program: enabling "covered entities to stretch scarce federal resources as far as possible, reaching more eligible patients and offering more comprehensive services".  Achieving the intent of the 340B program is more important now than ever before. Federal resources are indeed scarce; there will be many, many new individuals looking to safety net providers for care in the near future.

Ensuring the health of your patients, staff, 340B program, and pharmacies is our top priority. DPC remains committed to providing flexible, customized pharmacy services to support you during this challenging and rapidly evolving global crisis. Thank you for the good work you do every day! We're here to help when you need us.

For official guidance from HRSA, please visit: www.hrsa.gov/opa/COVID-19-resources