Unexpected Uncertainty For The 340B Drug Pricing Program

Law360, New York (February 3, 2016, 12:55 PM EST) -- Alyce C. Katayama

Elizabeth R. Gebarski Just when we have all heard more than enough about the threats facing the 340B Drug Pricing Program, along comes the Bipartisan Budget Act of 2015 (BBA 2015). BBA 2015 does not even mention the 340B Program. However, it changes the way in which new off-campus hospital outpatient departments (HOPDs) will be paid on or after Jan. 1, 2017, and this change could have a substantial impact on 340B Program child site eligibility for the child sites of certain 340B covered entities (CEs).

Background

First, a little history. Before Nov. 2, 2015, Medicare generally paid...

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