Ep 51 | CMS Medicaid Drug Rebate Program & “Covered Outpatient Drug” Definition
340B Unscripted21 Elo 2024

Ep 51 | CMS Medicaid Drug Rebate Program & “Covered Outpatient Drug” Definition

In this episode, Greg and Rob are joined by healthcare attorney Todd Nova to discuss a proposed rule change put forth by CMS in 2023 regarding the Medicaid Drug Rebate Program (MDRP), which includes a potential change to the definition of “covered outpatient drug”. They’ll discuss how covered entities have historically interpreted the definition of covered outpatient drugs, and what impact might come from CMS’s proposed change in this definition. Greg and Rob also get Todd’s take on recent HRSA audit activity in a post-Genesis 340B environment.

In the intro, the guys discuss the recent announcement of Medicare prices on the first 10 drugs subject to IRA-mandated drug price negotiations, a court ruling in Texas over DSH% calculation and use of Section 1115 waiver days, and changes to claims submission via 340B ESP.

Jaksot(96)

Ep 90 | 340B Updates

Ep 90 | 340B Updates

In this episode, Greg and Rob catch up on various developments happening in the 340B community. Topics discussed include the proliferation of manufacturer claim submission requirements, notable court ...

20 Huhti 42min

Ep 89 | 340B Pricing Removal & GPO Prohibition Court Case Ruling

Ep 89 | 340B Pricing Removal & GPO Prohibition Court Case Ruling

In this episode, Greg and Rob discuss reports of 340B pricing removal from wholesaler accounts, which may be related to recent manufacturer claim submission requirement policies.  They also catch up o...

6 Huhti 51min

Ep 88 | Hospital Child Sites – Recent Developments with CMS Provider-Based Rules and 340B Child Site Eligibility Timing

Ep 88 | Hospital Child Sites – Recent Developments with CMS Provider-Based Rules and 340B Child Site Eligibility Timing

In this episode, Greg and Rob are joined by returning guest, healthcare attorney Jeff Davis. They’ll be discussing the CMS provider-based rule changes coming out of the 2026 Consolidated Appropriation...

16 Maalis 51min

Ep 87 | HRSA 340B Rebate Request For Information (RFI)

Ep 87 | HRSA 340B Rebate Request For Information (RFI)

In this episode, Greg and Rob are joined again by healthcare attorney Todd Nova to discuss the recent HRSA Request For Information (RFI) related to a potential future 340B rebate model pilot. They dis...

10 Maalis 1h 9min

Ep 86 | Updates in 340B

Ep 86 | Updates in 340B

In this episode, Greg and Rob catch up on various looming deadlines for 340B providers.  That includes submitting responses to the HRSA 340B Rebate Request For Information (RFI), as well as submitting...

2 Maalis 34min

Ep 85 | HRSA Information Collection Request – 340B Enrollment, Registration & Recertification

Ep 85 | HRSA Information Collection Request – 340B Enrollment, Registration & Recertification

In this episode, Greg and Rob are joined again by healthcare attorney Emily Cook. They discuss a recent HRSA Information Collection Request (ICR) that describes some changes being made to the 340B enr...

2 Helmi 58min

Ep 84 | CMS OPPS Drug Acquisition Cost Survey (ODACS)

Ep 84 | CMS OPPS Drug Acquisition Cost Survey (ODACS)

In this episode, Rob and Greg are joined by guest Andy Ruskin, healthcare attorney and government payer expert from K&L Gates. They’ll be discussing the 2026 CMS OPPS Final Rule, focusing on the provi...

26 Tammi 1h 3min

Ep 83 | 340B Rebates Are on Hold

Ep 83 | 340B Rebates Are on Hold

In this episode, Greg and Rob share some initial reactions around the recent judicial activity affecting HRSA's 340B rebate model. They'll discuss thoughts on the federal court ruling that halted the ...

12 Tammi 27min

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