What is the 340B Drug Pricing Program and why is it important?
The 340B Drug Pricing Program requires drug manufacturers to sell outpatient prescription drugs to eligible safety-net providers such as Salina Family Healthcare Center (SFHC) at reduced prices. Before 340B existed, it was a common voluntary practice for drug manufacturers to sell their drugs at reduced prices to safety-net providers. When the Medicaid Drug Rebate Program became law in 1990, this practice ended and caused a significant strain on these providers and their patients. Section 340B of the Public Health Service Act was created in 1992 to fix this unintended consequence. Safety-net providers use the savings received from buying through the 340B Program to help patients afford their prescriptions and have access to more and better patient services. SFHC uses the 340B Program for multiple prescription savings programs such as our “purple card” discount program that can be found here. We also use the 340B Program to afford vital patient services such as free prescription delivery through our entity-owned pharmacy, enhanced clinical pharmacy services to assist our providers and patients with prescription management, and in-house Care Coordinators that provide patient financial resource assistance. These and the other 340B-supported patient services at SFHC are so important to the care of our patients. Without them, more patients would get sick and end up in the hospital or even worse.
What has happened recently that could hurt the 340B Drug Pricing Program?
There have been multiple issues over the last year that have caused concern for the 340B Drug Pricing Program. About one year ago, several drug manufacturers began restricting how their drugs can be purchased through the 340B Program. You can read more about that here and also here. In addition, the Trump administration issued a late Executive Order at the end of their term mandating health centers such as Salina Family must pass along the 340B price to patients on insulin and EpiPen prescriptions. On the surface, this sounds like a good thing. If you read this blog post, however, you’ll understand this Executive Order was not needed and would likely do more harm than good. A third issue for the 340B Program involves for-profit Pharmacy Benefit Managers (PBMs) siphoning money from the 340B Program at the expense of safety-net providers and their patients for their own gain. This issue did not start during the last year but did get worse and contributed to the drug manufacturer actions mentioned earlier. An opinion piece posted to a website that tends to be critical of the 340B Program explains this problem here.
What is being done to stop this and how can I help?
There have been multiple efforts to push back against these problems ranging from grassroots politics and public relations campaigns to lawsuits. The Health Resources and Services Administration (HRSA) who oversees the 340B Drug Pricing Program recently responded to the drug manufacturers refusing to sell their drugs for use at contract pharmacies through the 340B Program by sending them letters warning there would consequences if they do not stop. You can read more about that here. Unfortunately, as of June 8, 2021, the drug manufacturers have not complied with the letter and have further challenged the 340B Program through additional lawsuits. The Trump administration’s misguided Executive Order is being discussed by the Biden administration with involved stakeholders. Derek Pihl, Executive Director of Pharmacy Services at Salina Family, had the opportunity to speak to the Biden administration’s Office of Management and Budget (OMB) about Salina Family’s support of the Executive Order being canceled. The Biden administration seems to understand this Executive Order was not necessary and will hopefully rescind the rule soon. In terms of PBMs profiting from the 340B Program at the expense of patients, federal legislative efforts to stop this have failed to this point but have succeeded at the state-level in 14 states. Unfortunately, Kansas is not one of them but there is hope that could change. That’s where you can help. There is a new organization called “Community Voices for 340B” that has been formed to educate about the importance of the 340B Program and what it does to improve our health care system. Please consider visiting this educational website and learning more about what you can do to help protect 340B by going to https://www.cv340b.org/. You can also let both our state-level and federal-level elected officials know you have concerns about the 340B Program and its continued ability to serve people. Policymakers hearing from patients about their concern over the 340B issues mentioned above would be extremely powerful and helpful. Find your state-level legislators by going to https://openstates.org/ks/, your federal representative by going to https://www.house.gov/, and contact information for your Kansas Senators by going to https://www.senate.gov/states/KS/intro.htm.
