HFMA submitted comments to CMS on the proposed rule,Medicare Program; Hospital Outpatient Prospective Payment System: Remedy for the 340B-Acquired Drug Payment Policy for Calendar Years 2018–2022 . In the letter, HFMA stated its support of the following aspects of the proposed remedy:
- The implementation of a single lump-sum reimbursement to hospitals, covering underpayments for outpatient drugs procured under the 340B Drug Pricing Program during the period spanning calendar years (CYs) 2018 to 2022.
- The agency’s commitment to providing hospitals with compensation equivalent to the beneficiary cost-sharing that hospitals would have originally received.
- The well-designed methodology outlined for the determination of owed amounts to 340B hospitals, which significantly reduces administrative complexities.
HFMA also urged HHS to review certain aspects of the proposed remedy that currently exhibit deficiencies, thereby imposing additional strain on 340B entities and the communities they support, including:
- HHS’s suggested “Budget Neutral Adjustment” remedy, aimed at countering the Supreme Court’s mandated resolution.
- The failure to address inadequate Medicare Advantage (MA) plan reimbursement for 340B-acquired drugs by 340B entities from 2018 to 2022.