State Medicaid Policies and Duplicate Discounts

Many covered entities rely on the revenue they receive when they or their contract pharmacies dispense 340B drugs to a Medicaid managed care enrollee and bill the Medicaid managed care plan or, more likely, the plan’s pharmacy benefit manager (PBM).  Many states, however, are pursuing a range of strategies to transfer the benefit of the 340B program from covered entities to themselves.  Among them are the following:

• Carving out pharmacy services from the managed care benefits package and administering the pharmacy benefit on a fee-for-service (FFS) basis where retail drugs are automatically subject to actual acquisition cost reimbursement under federal law;
• Refusing to recognize contract pharmacies which effectively forces the pharmacies to carve out both FFS and managed care drugs from the covered entity’s 340B program;
• Incentivizing or even requiring Medicaid PBMs to reimburse 340B drugs at reduced levels so that the state can pay lower capitation rates to the plans; and
• Subjecting covered entities and their contract pharmacies to point-of-sale claims identification requirements that cannot be met due to the retroactive nature of replenishment-based virtual inventory systems.

Other states, most notably Oregon, have developed 340B-friendly policies that facilitate use of 340B drugs to fill Medicaid managed care prescriptions.

This one-hour webinar will feature the Executive Director of HIV Alliance, an RWC-340B member from Oregon, who will discuss her organization’s experience with Oregon’s unique model for identifying 340B claims retroactively.  The webinar will also include a panel of Powers attorneys who will discuss strategies for combating problematic Medicaid policies and protecting continued use of the 340B program for Medicaid populations.

Who will benefit from this webinar?

• Chief Executive Officers
• Chief Financial Officers
• Compliance Officers
• Pharmacists
• 340B Managers
• Government Relations Professionals