The Alliance for Integrity and Reform of 340B (AIR-340B), an advocacy group funded by the pharmaceutical industry and oncologists, has told Congress how to scale back the 340B Program.

The group delivered a letter to the leaders of the House and Senate committees that have jurisdiction over the program demanding increased oversight of, and legislative changes to, the 340B Program.  The letter, which is hosted on the AIR-340B web site, is signed by multiple physician and patient advocacy groups that are allied with AIR-340B, several of whom have not previously been engaged on 340B.

The signers are as follows:  Alliance for Patient Access, Colon Cancer Alliance, Log Cabin Republicans, National Center for Policy Analysis, National Council of Asian Pacific Islander Physicians, National Hispanic Medical Association, National Medical Association, RetireSafe, The AIDS Institute, The Galen Institute, and The National Hispanic Council on Aging (NHCOA).  The letter is a watershed moment in PhRMA’s seven-year build up to 340B reform, as it represents the first public demand for specific legislative action.  If AIR-340B is successful in its advocacy efforts, the changes they seek would have a significant impact on your Ryan White clinics.  The changes would also erode support for the program, leaving it vulnerable to eradication in the future.

We are most troubled by two statements in the letter:

• The letter regurgitates PhRMA’s false narrative regarding the intent of the 340B program, stating matter-of-factly that the original intent of the 340B Program was to help uninsured patients, and suggesting that the level of charity care provided by an entity should determine whether the entity is eligible for 340B discounts.  This message is particularly dangerous to Ryan White clinics, since some believe that you should only be able to use 340B drugs when the Ryan White program is the payer on a claim.  Though it is demonstrably false, AIR-340B repeats the idea often enough to reinforce their dangerous view that 340B savings should only be used to pay for drugs for the uninsured.

• The letter seeks to place limits on the role of contract pharmacies in the 340B Program.  Many Ryan White clinics depend on contract pharmacies to dispense 340B drugs, and limiting the role of contract pharmacies could significantly affect a clinic’s ability to access 340B discounts.

AIR-340B also hosted a congressional briefing along with Rep. Chris Collins (R-NY) this morning in which the group made similar points about the intent of the 340B Program and the need for limitations on contract pharmacies.  In addition, PhRMA suggested at the meeting that the Trump administration should re-issue the 340B Mega-Guidance, which was withdrawn earlier this year.  Many covered entities, including Ryan White clinics, expressed concern that the proposed Mega-Guidance would result in restrictions on the 340B Program that were inconsistent with its statutory purpose.  If PhRMA is interested in resuscitating it, the group must believe it can get a favorable product.  The briefing was attended approximately 25 congressional staffers.  Click here to view a handout distributed to attendees of the meeting.