The Future of 340B: It's All About Perspective
Over the past few months, there has been much media attention surrounding the 340B Drug Discount Program. Established more than 20 years ago, this legislation was enacted to assist different health care settings in providing excellent care for indigent and vulnerable patients. To allow this to happen, safety net providers have access to discounted outpatient drugs from manufacturers. By being able to purchase the discounted medications, these qualifying organizations are able to utilize the savings to provide care for those uninsured and underinsured patients.
Unfortunately, some of the safety net providers have been targeted with intimations that they have inappropriately taken advantage of opportunities that allow for beneficial financial terms. This money ends up benefitting organizations and executives, not the people it was intended to serve, suggest the critics. I am aware of these concerns as I am employed by an organization that qualifies for the 340B Drug Discount Program.
One example of abuse that is frequently mentioned by those highlighting the concerns is chemotherapy and specialty pharmacy drugs. It is well recognized that these medications are extremely expensive. If a safety net provider can get access to these medications at a significant discount, they might take advantage of these incentives to expand the number of oncology clinics and treat as many patients in the outpatient setting as possible. In addition, as opposed to having these patients receive their medications from a community pharmacy, a requirement could be implemented for the patients to receive their medications through a safety net provider’s mail order pharmacy as it benefits the hospital’s bottom line. Depending on the volume and type of medications dispensed, significant revenue could be realized.
Another recent noted abuse is through the use of contract pharmacies. In 2010, guidelines were issued that allowed for the establishment of multiple contract pharmacies with 1 covered entity. This has led some institutions to contract directly with chain drug stores. If a patient presents to one of these stores with a legitimate prescription that would qualify for a 340B-priced medication, that pharmacy can replenish that medication dispensation with a 340B-priced medication as opposed to the price usually paid. While there are numerous activities that need to occur behind the scenes to make this process legitimate to withstand an audit, this is another example that critics point to when they suggest that current practice has strayed from the original intent of the legislation.
If you can strip away all of the politics that lead to the tension around the topic, there are 2 things that everyone needs to remember—there are underserved patients among us, and the illegality of these activities. Anybody who gets sick in our country should be able to receive the best care available, even if they cannot afford it.
One way to stretch our limited resources is to subsidize those who have an expressed mission to care for those less fortunate. If they can do that while legitimately and legally following the regulations that are currently in place, these organizations should not be pressured to operate any differently or be highlighted in the popular press. They should not be made to feel guilty for doing what is allowed under the law and improving care for the less fortunate. Let these organizations utilize the opportunities to provide high-level care to the unfortunate, as none of us want to be in that situation.
Politics will continue to place scrutiny on the current regulations, and changes will probably occur, but if you work at an organization that qualifies for the 340B Drug Discount Program, you should be proud to work at a place that has a mission to serve the less fortunate. I know I do.
Stephen F. Eckel, PharmD, MHA, BCPS, FASHP, FAPhA, is associate director of pharmacy, University of North Carolina Hospitals and clinical associate professor, University of North Carolina Eshelman School of Pharmacy.He was elected the chair of the Acute Care Practice Forum and board member for the North Carolina Association of Pharmacists. He served for many years in the American Society of Health-System Pharmacists (ASHP) House of Delegates.