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Covered Entity SearchStart at www.hrsa.gov/opa
Click on this link
Click on this link
Select the entity type and enter data to find a specific entity
CE Decision to Not Use 340B DrugsCarve-Out
When a CE enrolls, its data are entered in the CE database.
If the entity is NOT using 340B-purchased drugs for their Medicaid fee-for-service patients, the form will indicate that the entity will not bill Medicaid for drugs purchased at 340B prices.
CE Data
Most contract pharmacies and Medicaid agencies do not “establish an arrangement to prevent duplicate discounting.”
Medicaid reimbursement formulas based on actual 340B cost may not provide margin sufficient to cover costs.
Most clinics and pharmacies are aware that the Medicaid anti-kickback statute is very broad and are wary of including Medicaid prescriptions in their contracts.
The Medicaid Exclusion File
Reasons why most 340B entities exclude Medicaid prescriptions from their contract pharmacy:
CE Decision to Use 340B DrugsCarve-In
If the entity is using 340B-purchased drugs for their Medicaid fee-for-service patients, the form must display the Medicaid number and state.
When a CE enrolls, its data are entered in the CE database.
CE Data
When a CE Has More Than One NPI
The OPA database is capable of handling entities that have more than 1 NPI and wish to bill different state Medicaid agencies in a different manner (e.g., carve-out in 1 state, and use 340B for another). On the registration form, the entity must specify that the NPI is listed in association with particular states.
When a CE enrolls, its data are entered in the CE database.
CE Data
Alternative Agreement With State
The CE must work with its state Medicaid agency and OPA to establish sufficient safeguards.
To the extent that a CE is either:
Unable to comply with standard methods discussed
for reporting NPI
Wishes to utilize an alternative method that
will also prevent a duplicate discount OR
Medication Exclusion File Data ExtractGo to: http://opanet.hrsa.gov/opa/default.aspxClick on “Search Medicaid Provider Numbers”
http://opanet.hrsa.gov/opa/CEMedicaidExtract.aspx
Medicaid Exclusion File Data
Go to http://opanet.hrsa.gov/opa/MedicaidExclusionFiles.aspx or the OPA’s home page and click on “Medicaid Exclusion Files”
It is ultimately the responsibility of the 340B participating entity to ensure accurate reporting of Medicaid billing of any 340B drugs to OPA and the state
Medicaid agency.
Work with the Medicaid agency(ies)
- 340B drugs identified - Rebates foregone
Medicaid provider number used to bill Medicaid for all
340B-purchased drugs(e.g., entity may not “pick
and choose”)
If the appropriate Medicaid billing number is not listed on the OPA database and 340B drugs are used to fill
Medicaid prescriptions, the entity should contact OPA immediately, so that the correct number can be
included on the OPA exclusion file database
The posted database information should be
correct at all times. Any changes to how an entity bills
Medicaid or inaccuracies in the Medicaid Exclusion File must be reported to OPA
immediately
CE Responsibility for Avoiding Duplicate Discounts
Avoiding Duplicate Discounts
What can CEs and states do to avoid Duplicate discounts on 340B drugs?
CEs States Become knowledgeable about duplicate
discount prohibition by using HRSA and Prime Vendor Program (PVP) resources
Evaluate your Medicaid billing practices: are you using 340B medications in ANY Medicaid prescriptions?
Review your entry in the OPA database: does it correctly match your practices?
Become knowledgeable about duplicate discount prohibition by using HRSA and PVP resources
Have a knowledgeable 340B “go-to” person in the state Medicaid office who is available to communicate with 340B entities
Review the Medicaid Exclusion File If discrepancies are noted, contact the CE
for more information Provide clear direction to CEs about your
Medicaid 340B reimbursement policy and their responsibilities
Let OPA know if there are concerns or areas for improvement
Office of Inspector General (OIG) ReportJune 2011
Department of Health and Human Services OIG
surveyed 50 state and DC Medicaid agencies about
their policies and oversight activities related to 340B-
purchased drugs
Findings • 25 states have no written
Medicaid 340B-reimbursement policy
• Over half developed alternatives to using the Medicaid Exclusion File
OIG Recommendations• Centers for Medicare &
Medicaid Services (CMS) should develop written Medicaid 340B policies
OIG Recommendations• HRSA, in conjunction with
CMS, should improve accuracy and utility of Medicaid Exclusion File
OIG. State Medicaid policies and oversight activities related to 340B-purchased drugs. June 2011. OEI 05-09-00321. Available at: http://oig.hhs.gov/oei/reports/oei-05-09-00321.pdf. Accessed November 22, 2011.
340B Resource Information
https://www.340bpvp.com/
http://www.hrsa.gov/opa/
http://www.hrsa.gov/publichealth/clinical/patientsafety/index.html
ApexusAnswers@340bpvp.com 1-888-340-2787
Health Resources and Services Administration
340B Prime Vendor Program Managed by Apexus
Health Resources and Services AdministrationOffice of Pharmacy Affairs
340B Peer-to-Peer Program
Thank you for viewing this 340B tutorial developed by :
You can view additional 340B educational products and tools specifically developed to assist 340B-participating entities create and maintain processes to ensure 340B
program integrity at:www.hrsa.gov/opa/peertopeer/
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