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

Episoder(94)

Ep 41 | 340B News & Notes

Ep 41 | 340B News & Notes

In this episode, Rob and Greg catch up on a cluster of developments in the 340B space, including updates to manufacturer contract pharmacy restrictions, thoughts on a federal appellate court ruling on...

25 Mar 202429min

Ep 40 | Getting to Know the HRSA DRL: DRL 5 Purchasing Documentation and DRL 7 Entity-Owned Pharmacy Documentation

Ep 40 | Getting to Know the HRSA DRL: DRL 5 Purchasing Documentation and DRL 7 Entity-Owned Pharmacy Documentation

In this episode, Greg and Rob continue reviewing data solicited by HRSA during an audit. DRL #5 is purchasing documentation, including a list of accounts, sample invoices, and 340B purchase order deta...

11 Mar 202448min

Ep 39 | A Revisit of Ongoing Contract Pharmacy Restrictions

Ep 39 | A Revisit of Ongoing Contract Pharmacy Restrictions

In this episode, Greg and Rob are once again joined by SpendMend team member Riley Protz, to catch up on the current state of ongoing manufacturer restrictions on 340B contract pharmacy operations, as...

26 Feb 202432min

Ep 38 | Getting to Know the HRSA DRL:  DRL 4 Provider List and DRL 6 Contract Pharmacy Documentation

Ep 38 | Getting to Know the HRSA DRL: DRL 4 Provider List and DRL 6 Contract Pharmacy Documentation

In this episode, Greg and Rob continue their review of items from the HRSA audit data request list (DRL). They’ll cover DRL #4, the provider list, as well as DRL #6, contract pharmacy documentation.  ...

12 Feb 20241h 4min

Ep 37 | Getting to Know HRSA DRL: Part 3 - 340B Universe Data

Ep 37 | Getting to Know HRSA DRL: Part 3 - 340B Universe Data

In this episode, Greg and Rob continue to cover the HRSA data request list, focusing this week on DRL item #3, probably the most complex of all of the sections – 340B universe data. They’ll talk about...

29 Jan 20241h 6min

Ep 36 | Getting to Know HRSA DRL: Part 2 - CE Eligibility Documentation

Ep 36 | Getting to Know HRSA DRL: Part 2 - CE Eligibility Documentation

In Episode 36, Greg and Rob provide updates on recent 340B news around state legislation, manufacturer restrictions, and HRSA's decision to not appeal the Genesis case court ruling. They also provide ...

15 Jan 202443min

Ep 35 | Top 10 Developments in 340B for 2023

Ep 35 | Top 10 Developments in 340B for 2023

For our last episode of 2023, Greg and Rob reviewed hot topics impacting 340B covered entities from the past year.

18 Des 20231h 5min

Ep 34 | Maintaining 340B Compliance: The Importance of Self-Auditing

Ep 34 | Maintaining 340B Compliance: The Importance of Self-Auditing

In this episode, Greg and Rob are joined by Spendmend colleague Cat Eriksen (16:11) to discuss the importance of self-auditing as part of a 340B covered entity’s overall compliance strategy. They’ll t...

4 Des 202344min

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