On March 5, 2010, the federal Office of Pharmacy Affairs (“OPA”) released new final guidelines for the utilization of contract pharmacies for the dispensing of drugs under the prescription drug discount program established under Section 340B of the Public Health Service Act (the “340B program”). The new guidelines authorize entities that are eligible to participate in the 340B program (“340B covered entities”) to utilize multiple contract pharmacies instead of limiting them to a single point for pharmacy services. Proposed guidelines for multiple contract pharmacy arrangements were originally published more than three years ago, in January 2007.