The MHA submitted comments to U.S. Sens. Debbie Stabenow (D-MI), John Thune (R-SD), Shelley Moore Capito (R-WV), Jerry Moran (R-KS), Tammy Baldwin (D-WI) and Benjamin L. Cardin (D-MD) on proposed changes to the 340B Drug Pricing Program. The discussion draft circulated by this group follows their 2023 340B Request for Information, which also received comment from the MHA.
The Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of (SUSTAIN) 340B Act discussion draft includes several key provisions that would impact the 340B program. Specifically, the draft aims to address contract pharmacy arrangements, the definition of a patient for purposes of 340B, transparency, recognition of 340B child sites, program integrity, prevention of duplicate discounts, enhancing equitable treatment of program entities, user fees and implementation details. The MHA is pleased to be a part of these important discussions and appreciates the opportunities presented to weigh in on any changes to the program.
The MHA commentary on the discussion draft and suggested changes to the program include:
- Ensuring 340B covered entities can contract with pharmacy partners to the extent that best serves their individual needs.
- Opposing restrictions to a covered entity’s ability to contract with a pharmacy of their choosing.
- Including a broad definition of patient to meaningfully impact drug affordability for individuals served by 340B hospitals.
- Cautioning against new reporting or transparency requirements given existing requirements on participants and the need to protect against new administrative requirements and burdens on Michigan 340B hospitals. Covered entities should be able to share and tell their 340B stories and information in the manner that best fits each individual entity.
- Broadly accepting child sites for purposes of the program. Healthcare delivery continues to evolve and child sites are an opportunity to deliver care to patients in a space that makes the most sense to both the program participant and the patient themselves. Recognition of child sites within the context of 340B improve and increase access to care for vulnerable populations.
- Maintaining existing structure that allow covered entities to assess and prevent duplicate discounts. This includes partnership between all program participants when it comes to information sharing to ensure integrity while identifying both state and federal opportunities to better understand and streamline prevention of duplication of discount.
- Opposing the implementation of a user fee while supporting appropriations for administration of the program.
Members with questions on 340B advocacy and engagement can reach out to Elizabeth Kutter at the MHA.