340B/Medicaid Duplicate Discount Risk is Greater Than Ever

Over the past year, we here at CiiTA have become increasingly concerned about the potential 340B/Medicaid duplicate discount risk to manufacturers. We recently looked into this for a couple of our clients and found what amounts to a perfect storm of insidious financial exposure: 1) a surge in eligible claims thanks to the ACA-directed Medicaid rebate expansion; 2) the proliferation of Medicaid MCOs that managing pharmacy claims but with limited understanding of 340B; and 3) rapid growth in the number of 340B contract pharmacies that have little ability – and no financial incentive – to keep Medicaid claims separate from 340B.

HRSA and CMS are trying to provide clarity and direction when it comes to duplicate discounts.  Most notably, both agencies support a proposal to make the Medicaid MCOs themselves responsible for 340B duplicate discount prevention, yet neither agency has created a mechanism for MCOs to accomplish this. Instead both CMS and HRSA are leaving it to the plans to figure out.

To help us all get a sense of the growing duplicate discount problem, we have written a whitepaper that frames the issue and suggests some steps manufacturers can take to get a handle on their exposure. You can download it by clicking here:  340B/Medicaid Duplicate Discount Risk