On June 14, 2019, RWC-340B submitted a letter to Captain Krista Pedley, director of the Office of Pharmacy Affairs, contesting HRSA’s multisite registration policy that will adversely affect the registration, contracting, and inventory management practices for Ryan White Clinics (RWCs) and other non-FQHC federal grantees that operate multiple clinics. Based on our communications with Apexus, HRSA recognizes parent/child relationships only for hospitals, FQHCs, and FQHC “look-alikes.” Accordingly, all non-FQHC grantees must register each location that is operating under a single grant as a separate covered entity with a unique 340B identification number on OPAIS. Because each location is considered a separate covered entity, the location must maintain separate 340B inventories and enter into separate contract pharmacy agreements.
RWC-340B’s letter to Captain Pedley asked that HRSA reconsider its policy, and allow non-FQHC grantees the same flexibility that 340B hospitals and FQHCs are permitted for purposes of 340B registration, inventory purchasing, and pharmacy contracting. Not allowing RWCs and other non-FQHC grantees to register their secondary locations as child or affiliated sites creates unnecessary complexity and could make it more difficult for these clinics to fully utilize the 340B program.
Information about the multisite registration policy was communicated to us by Apexus, however neither HRSA nor Apexus has published this policy through guidance, FAQs, or otherwise.