K&L Gates Triage: 340B Update: CMS Issues Guidance for Avoiding Duplicate Discounts in Medicaid

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In this episode, Macy Flinchum and Victoria Hamscho discuss recent developments in the 340B Drug Pricing Program, including recent guidance by the Centers for Medicare and Medicaid Services on best practices for states to avoid duplicate discounts in Medicaid Fee-for-Service and Medicaid Managed Care Organization programs. The guidance largely lays out existing duplicate discount prevention strategies. However, it contains some recommendations that could greatly impact covered entities, such as using state plan amendments to limit the ability of some or all covered entities and/or contract pharmacies to use 340B drugs for Medicaid beneficiaries. As states implement these strategies, operational and compliance challenges may arise for covered entities, particularly for those that are filling prescriptions for Medicaid beneficiaries in multiple states with potentially differing requirements for identifying duplicate discounts.

Presenters: Macy Flinchum, Victoria Hamscho

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