RWC-340B commented on the Department of Health and Human Services (HHS) policy statement and request for information (RFI) published on May 16, 2018, titled “HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs.” While we share the objectives of lowering drug prices and reducing out of pocket costs, we do not agree with the implied assumptions included in many of the questions that the 340B program is a cause for rising drug prices. We also believe the 340B program is working as Congress intended and does not need the kind of “wholesale reform” advocated by some within the pharmaceutical industry.

The 340B program is critically important to Ryan White Clinics (RWCs) and their patients, allowing them to stretch their scarce resources to support the full continuum of care that their patients need including testing, linkage to care, treatment, retention, case management, and medication adherence. The program allows these services to be provided at little or no cost to needy patients. Many of these services are not reimbursed by any payer, though these services directly enable people living with HIV/AIDS to access and remain in care and, most importantly, to become virally suppressed so they cannot transmit the virus to others.

RWCs have made great progress in the fight against HIV/AIDS, but that progress is fragile and highly dependent on the continued viability and health of the 340B program and RWC’s access to 340B savings. Such progress means HIV-infected patients are living longer, but are often facing age-related diseases that set in earlier and require continued intensive and comprehensive services. The 340B program is helping RWCs win the battle against the HIV/AIDS epidemic and any narrowing of 340B utilization will undermine that battle.

To read the full comments, click here: RWC-340B response to RFI on HHS Blueprint on Drug Pricing.