The 340B Program faces challenges from both suppliers and payers. Dozens of drug manufacturers have unilaterally blocked shipment of 340B drugs to “contract pharmacies”, i.e., independent, chain and/or mail order pharmacies under contract with 340B hospitals and clinics to receive and dispense 340B drugs on their behalf. Meanwhile, pharmacy benefit managers and other payers have cut reimbursement to 340B pharmacies or subjected them to other restrictive contracting practices. These threats have led to a proliferation of federal lawsuits and calls for reform by some members of Congress, but resolution is still years away. Frustrated with federal inaction, state legislatures have jumped into the fray by passing laws that, on the one hand, protect 340B contract pharmacy arrangements and prohibit discriminatory contracting by payers and, on the other, subject 340B providers to greater transparency and accountability. Our speakers will summarize and analyze these federal and state 340B developments, their impact on the supply chain and reimbursement practices, and where these trends are likely to lead. 

Learning Objectives

1. Describe current legislative and litigation activities at the federal and state levels that will likely shape the future of the 340B Program.

2. Analyze the implications of these program trends on the supply chain and third party payers.

3. Evaluate strategies available to 340B hospitals and clinics for mitigating current threats.

4. Identify future threats to the 340B Program and solutions for your organization.

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