11/5/2024 – Beginning December 2, 2024, Boehringer Ingelheim Pharmaceuticals, Inc. (BI) will require covered entities to submit 340B claims data to 340B ESP™ for a single contract pharmacy. This policy applies to all covered entity types. This announcement, released on November 1, 2024, states that all data must be submitted within 45 days of the dispense date. Otherwise, BI’s current contract pharmacy policy remains unchanged, including the requirement that the contract pharmacy be within a 40-mile radius of the covered entity. BI’s 340B ESP™ announcement does not state whether covered entities in states that have adopted a law protecting delivery of 340B drugs to contract pharmacies are exempt, but at least one Arkansas covered entity received a notice stating that covered entities in Arkansas and West Virginia are exempt.

BI’s policy also states that a designated contract pharmacy may not replenish BI drugs based on the collective dispensing activity of non-designated contract pharmacies. BI states that it expects 340B products to be shipped directly to the same contract pharmacy location that dispensed to an eligible patient.

The Powers 340B team will continue to monitor manufacturers’ restrictive contract pharmacy policies.