Podcasts about 340b

This podcast will provide members with an update on federal and state action on the 340B program. We'll talk through 340B policy shifts at the federal level and what's happening in the states. We'll also discuss what we're watching as 340B cases make their way through the courts.  The information presented during the podcast reflects solely the opinions of the presenter. The information and materials are not, and are not intended as, a comprehensive source of drug information on this topic. The contents of the podcast have not been reviewed by ASHP, and should neither be interpreted as the official policies of ASHP, nor an endorsement of any product(s), nor should they be considered as a substitute for the professional judgment of the pharmacist or physician.

Heather and Matthew welcome Chuck Melendi, a seasoned healthcare consultant and former executive with decades of experience in pharmaceuticals, biotech, and medical devices. Chuck joins us to examine the complexities of the federal 340B pricing program, which provides discounted outpatient drugs to eligible health care providers. From ongoing litigation and proposed legislative reform to the role of PBMs, Chuck shares insights into why a seemingly good faith regulation is one of the most debated topics in health care policy. Tune in for a thoughtful discussion on how healthcare leaders and government can preserve the mission of 340B while addressing its challenges.

In this episode, Greg and Rob catch up on developments in the 340B space. They chat about new information provided by CMS for pharmacies related to the Medicare Drug Price Negotiation Program (some helpful links are below). Also, they debate about what might be coming with the widely anticipated 340B rebate model guidance. CMS Medicare Transaction Facilitator (MTF) User Guide: https://www.cms.gov/files/document/negotiation-program-mtf-user-guide.pdf CMS MTF Pharmacy FAQs: https://340breport.com/wp-content/uploads/2025/06/pharmacy-and-dispensing-entity-mtf-faq.pdf  

After months of litigation in a federal district court, a key decision recently came out in the legal fight over 340B drug rebates. 340B Health Vice President of Legal and Policy Amanda Nagrotsky updates us on the development.Court deals a blow to drugmakersD.C. district court judge Dabney Friedrich ruled on May 15 that manufacturers cannot unilaterally implement rebate models for 340B, agreeing with the Health Resources & Services Administration (HRSA) that the agency effectively has preapproval authority over rebates. In her decision, the judge cited early results from a 340B Health survey finding that shifting 340B to a rebate model would divert significant hospital resources from patient care. Drugmakers have already appealed the ruling.Some bright spots for drugmakers in this decisionAlthough the decision largely went against pharmaceutical companies, the judge ruled that the 340B statute does not categorically prohibit rebates, leaving the door open for government approvals of rebates. The judge also agreed with drugmakers' assertions that HRSA should consider how rebate models could improve 340B compliance and how requiring the sharing of data through rebates could aid in drug company audits of covered entities.Will HRSA stop all rebates from proceeding?Despite this decision, the legal fight over rebates isn't over yet. The judge found that, for three of the manufacturers in these cases, HRSA has yet to issue final decisions with respect to their proposed rebate models. In the case of Sanofi, the judge found that HRSA failed to adequately explain the legal basis for rejecting the drugmaker's rebate model, and she directed the agency to reconsider its decision and explain whether and how it would violate the 340B statute. HRSA sent rebate guidance to the White House for approval earlier this month, though as of recording this episode it was not known what that guidance would say.ResourcesRead Our Analysis of the First Federal Court Decision on Rebates340B Health Continues Court Fight Against Rebates

In this episode, Garrick J. Stoldt, CFO of Saint Peter's Healthcare System, shares how his team is tackling major challenges including Medicaid cuts, 340B pressures, and rising denials—while staying strategic about AI investments and future-proofing the system. With over 20 years at the helm, he reflects on the evolving role of the CFO and why proactive leadership is more essential than ever.

This week's episode is a quick one. We pushed out this episode expecting to have HRSA guidance on rebate models to discuss, but we'll have to wait for that topic another day! Greg and Rob catch up on a few developments in the 340B news cycle, primarily recapping HRSA's first final agency action taken in the context of 340B ADR claims.  

More than a third of patients released from the hospital never fill their discharge prescriptions, but “meds-to-beds” programs can help improve that statistic. That is the approach Renown Health in Reno, Nev., took with the help of its 340B savings. Renown Vice President of Pharmacy Services Adam Porath joins us to describe how this meds-to-beds program improves patient care.Hospital readmissions down, patient convenience upRenown Health's 340B-funded program offers medication to patients who are being discharged from the hospital, either through bedside delivery, pneumatic tube, or a unique discharge lounge. The effort began as a pilot for Medicaid patients in 2016, and it demonstrated patients in the program were 25% less likely to be readmitted to the hospital once discharged. These health improvements plus the added convenience of medication access for patients convinced the system to expand the program.340B pricing to patients who cannot payPorath says Renown Health refers patients who cannot afford discharge medications to its social services team, which can authorize providing the drugs to those patients at the 340B-discounted rate. The team also will work with patients to see if they qualify for coverage such as Medicaid or other programs to reduce their out-of-pocket costs. Porath said Renown's meds-to-beds program provides drugs free of charge to about 30 patients per month.The keys to successRenown Health's meds-to-beds program has been a success, with more than 80% of eligible patients participating as of the end of 2024. The hospital expanded the services to all patients and started operating it 24/7 in April 2024. Porath said the keys to success include regular reporting to stakeholders and innovations to handle a large volume of patients discharging at once. Such changes allow all parties to stay in the loop with the development of the program and to celebrate successes as they occur.ResourcesRead Our Analysis of the First Federal Court Decision on RebatesSecond Federal Judge Allows 340B Health, Member Hospitals To Intervene in Rebate Lawsuit

Rural Health News is a weekly segment of Rural Health Today, a podcast by Hillsdale Hospital. News sources for this episode: Alan Condon, “CMS cracks down on states using Medicaid to treat undocumented immigrants,” May 27, 2025, https://www.beckershospitalreview.com/finance/cms-cracks-down-on-states-using-medicaid-to-treat-undocumented-immigrants/, Becker's Hospital Review.  KFF Health News, “Health Provisions in the 2025 Federal Budget Reconciliation Bill,” Updated May 22, 2025, https://www.kff.org/tracking-the-medicare-provisions-in-the-2025-budget-bill/.  Donna Levally, “Four Changes to Medicare in the One Big Beautiful Bill Act,” Updated May 27, 2025, https://www.kiplinger.com/retirement/medicare/changes-to-medicare-in-the-one-big-beautiful-bill-act, Kiplinger. Chartis, “New Chartis Study Explores Rural Hospital Instability and Models Potential Impact of Rural Emergency Hospital Designation,” February 7, 2023, https://www.chartis.com/about/news/new-chartis-study-explores-rural-hospital-instability-and-models-potential-impact-rural. Madeline Ashely, et. al, “House GOP's 1,112-page budget: 23 notes for hospital leaders,” May 27, 2025, https://www.beckershospitalreview.com/uncategorized/house-gops-1112-page-budget-23-notes-for-hospital-leaders/, Becker's Hospital Review. Noam N. Levey, “In Arizona County That Backed Trump, Conflicted Feelings About Cutting Medicaid,” May 28, 2025, https://kffhealthnews.org/news/article/medicaid-cuts-arizona-county-trump-voters-conflicted/, KFF Health News. Modern Medicaid Alliance, “Opposition Continues to Grow As Proposed Medicaid Cuts Move Forward Through Reconciliation Process,” May 20, 2025, https://modernmedicaid.org/opposition-continues-to-grow-as-proposed-medicaid-cuts-move-forward-through-reconciliation-process/. Rural Health Today is a production of Hillsdale Hospital in Hillsdale, Michigan and a member of the Health Podcast Network. Our host is JJ Hodshire, our producer is Kyrsten Newlon, and our audio engineer is Kenji Ulmer. Special thanks to our special guests for sharing their expertise on the show, and also to the Hillsdale Hospital marketing team. If you want to submit a question for us to answer on the podcast or learn more about Rural Health Today, visit ruralhealthtoday.com. Follow Rural Health Today on social media! ⁠https://x.com/RuralHealthPod⁠⁠https://www.youtube.com/@ruralhealthtoday7665⁠  Follow Hillsdale Hospital on social media! ⁠https://www.facebook.com/hillsdalehospital/⁠ ⁠https://www.twitter.com/hillsdalehosp/⁠ ⁠https://www.linkedin.com/company/hillsdale-community-health-center/⁠ ⁠https://www.instagram.com/hillsdalehospital/⁠ 

Dr. Lisa Mathew interviews Dr. Brittany Panico, a rheumatologist in Colorado Springs who recently wrote an op-ed calling for reforms to the 340B program to require more transparency and reporting on how 340B discounts are passed on to patients. The 340B Program is a federal drug pricing program that allows certain hospitals and clinics to buy medications at steep discounts to support medication access for underserved patients, with the expectation that these savings would be passed on to patients. But critics argue that the program's growth has led to unintended consequences, such as market consolidation. And some studies suggest that 340B discounts may not translate into increased care or lower costs for vulnerable populations. Join Dr. Mathew and Dr. Panico as they discuss Dr. Panico's experience as an employed physician in a 340B hospital system and as an independent physician, and how the lack of oversight in the program may be making it harder for specialists to deliver the best patient care. Produced by Andrew Sousa and Hayden Margolis for Steadfast Collaborative, LLC Mixed and mastered by Hayden Margolis Gastro Broadcast, Episode 77, presented by TissueCypher from Castle Biosciences

In this episode, Greg and Rob are joined by guest Peggy Tighe, healthcare attorney and government relations specialist. They catch up on lots of contemporary issues impacting 340B providers, including state legislative activity (19:44), the recent Trump Administration's executive order on drug pricing (30:02), Senator Cassidy's 340B investigation report (43:20), and movement in 340B rebate litigation (52:00).   Also, listen for Dave Chappelle and magic mushroom references – this one was a lively discussion! Register for our upcoming Trulla Webinar: https://attendee.gotowebinar.com/register/7502684065481252181?source=340B+Unscripted Attending the 340B Grantees Spring Conference in Kansas City May 27 - 30? Come say hello to our team – we'll be at Booth #24 sharing our insights from our work with the 340B grantee community!

Big potential changes to how 340B operates plus heightened interest in both new protections and new restrictions for covered entities means there is much to keep track of in the 340B world. 340B Health CEO Maureen Testoni joins us to make sense of recent developments in the nation's courts and beyond.Rebates Get Their Day in Court340B Health, two member hospitals, and the government met drug companies in court in late April to challenge drugmaker attempts to replace 340B discounts with rebates. Testoni says the judge cited potentially devastating consequences to hospitals if rebates proceeded but also had probing questions for the government on how it is working to address drugmaker compliance concerns. The Dept. of Health and Human Services is set to release guidance by early June on the rebate issue, and the court's decision could come out soon.The White House Proposes 340B Big Oversight Shift A leaked copy of the Trump administration's latest budget proposal includes a plan to move the Office of Pharmacy Affairs (OPA) from the Health Resources & Services Administration to the Centers for Medicare & Medicaid Services. Testoni says the oversight shift is concerning because of a stark difference between the purpose of 340B and the operations of Medicare and Medicaid. CMS also imposed years of Medicare payment cuts to 340B hospitals that the U.S. Supreme Court eventually overturned.340B Protections, Mandates Take Center StageStates continue enacting laws to protect hospital access to 340B pricing, but they also are moving forward with reporting mandates and proposals to define how hospitals should use their savings. Testoni said reporting and use-of-savings mandates lead to misdirected views on the purpose of 340B, which goes far beyond direct patient care and cost assistance. On Capitol Hill, a report from a long-running investigation of 340B recently came out, contributing to the debate over possible new restrictions.ResourcesFederal Government Signals Upcoming Guidance on 340B Rebate Models Amid Legal ChallengesBrief Your Leaders on White House Plans for Major 340B ChangesNebraska Is 12th State To Enact Contract Pharmacy ProtectionsIndiana Becomes Fifth State To Mandate 340B Reports From HospitalsKey Senator Concludes 340B Investigation, Calls for Major ReformsNew 340B Health Research340B Impact Profiles

Once again, the venerable 340B Drug Pricing Program finds itself in the crosshairs of critics – this time, from the U.S. Congress.Recently, Sen. Bill Cassidy (R-La.), ranking member of the Senate Health, Education, Labor, and Pensions (HELP) Committee, released a report outlining his office's investigation into the program.During the next live edition of Monitor Mondays, 340B Health CEO Maureen Testoni will return to the broadcast to offer her response to the senator's investigation.The long-running broadcast will also include these instantly recognizable features:• Monday Rounds: Ronald Hirsch, MD, vice president of R1 RCM, will be making his Monday Rounds.• The RAC Report: Healthcare attorney Knicole Emanuel, partner at the law firm of Nelson Mullins, will report the latest news about auditors.• Risky Business: Healthcare attorney David Glaser, shareholder in the law offices of Fredrikson & Byron, will join the broadcast with his trademark segment.• Legislative Update: Cate Brantley, senior healthcare government affairs analyst for Zelis, will report on the news at the intersection of healthcare and congressional action.

President Donald Trump's April 15th executive order, “Lowering Drug Prices by Once Again Putting Americans First”, contained a smorgasbord of policy proposals targeting a variety of industry stakeholders. But how much legal force do these different elements have, and what are the concrete takeaways for pharma? To answer these questions and more, host Jonah Comstock once again welcomes Hogan Lovells attorney Alice Valder Curran to the podcast to pick apart the order piece by piece. They discuss the headline – Trump's intention to eliminate the Inflation Reduction Act's “pill penalty”, and talk about why the language is more ambiguous than it appears and could be good or bad news for pharma. They also talk about PBM reform, closing 340B loopholes, and how much the Federal government can really do to promote drug importation from Canada at the state level. Check out the podcast to learn everything you wanted to know about Trump's Executive Order.

The federal drug purchasing program known as 340B was created in 1992 to help select provider organizations stretch scarce resources to care for patients. More than three decades later, health systems of all shapes and sizes have come to rely on 340B for their financial sustainability. But the program has come under criticism. And in recent years, it's been under more scrutiny, with manufacturers, state governments, and federal regulators proposing changes to how it operates. In this episode, host Abby Burns invites Advisory Board experts Gina Lohr and Chloe Bakst to unpack the origin and controversy around 340B. They debate whether 340B has strayed from its intended purpose and break down the proposed changes to the program, how likely they are to go into effect, and what those changes would mean for health systems. Plus, stay tuned to the end of the episode, where co-host Rae Woods discusses the recent healthcare-focused executive order and what it signals for the future of this administration's drug policy. Let us know what you think about today's discussion, or share your ideas for future episode topics by leaving us a voice message or emailing us. Links: 340B Drug Pricing Program 340B reimbursement cuts may be looming: What you need to know J&J's 340B rebate model is receiving pushback. Here's why. Congress is weighing spending cuts. How will they impact healthcare? [Relentless Health Value] EP448 (Part 1): 340B: Where It Started, Where It Is Now, and Who Is Really Benefiting From This Massive Program, With Shawn Gremminger [Relentless Health Value] EP448 (Part 2): 340B: Why Employers Should Probably Care About What's Happening Here, With Shawn Gremminger GLP-1 innovation showcase A transcript of this episode as well as more information and resources can be found on RadioAdvisory.advisory.com.

The federal drug purchasing program known as 340B was created in 1992 to help select provider organizations stretch scarce resources to care for patients. More than three decades later, health systems of all shapes and sizes have come to rely on 340B for their financial sustainability. But the program has come under criticism. And in recent years, it's been under more scrutiny, with manufacturers, state governments, and federal regulators proposing changes to how it operates. In this episode, host Abby Burns invites Advisory Board experts Gina Lohr and Chloe Bakst to unpack the origin and controversy around 340B. They debate whether 340B has strayed from its intended purpose and break down the proposed changes to the program, how likely they are to go into effect, and what those changes would mean for health systems. Plus, stay tuned to the end of the episode, where co-host Rae Woods discusses the recent healthcare-focused executive order and what it signals for the future of this administration's drug policy. Let us know what you think about today's discussion, or share your ideas for future episode topics by leaving us a voice message or emailing us. Links: 340B Drug Pricing Program 340B reimbursement cuts may be looming: What you need to know J&J's 340B rebate model is receiving pushback. Here's why. Congress is weighing spending cuts. How will they impact healthcare? [Relentless Health Value] EP448 (Part 1): 340B: Where It Started, Where It Is Now, and Who Is Really Benefiting From This Massive Program, With Shawn Gremminger [Relentless Health Value] EP448 (Part 2): 340B: Why Employers Should Probably Care About What's Happening Here, With Shawn Gremminger GLP-1 innovation showcase A transcript of this episode as well as more information and resources can be found on RadioAdvisory.advisory.com.

The 340B program has been active for over 30 years and is dynamic and evolving. Dr. Greg Medley, Senior Director, 340B Drug Pricing Program Services at Vizient joins host Carolyn Liptak, Pharmacy Executive Director with the Vizient Center for Pharmacy Practice Excellence to discuss the impact of the most recent executive order on the 340b program.    Guest speakers:  Greg Medley, PharmD Senior Director, 340B Drug Pricing Program Services Vizient Inc.   Host:  Carolyn Liptak, MBA, , BS Pharm Pharmacy Executive Director, Center for Pharmacy Practice Excellence Vizient Inc.   Show Notes: [00:53-01:26] Dr. Medley background information  [01:27-03:17] What is outlined in the executive order [03:18-05:27] Basics of how 340B works and why its under fire [05:28-09:36] How this new executive order pertains to the 340B program  [09:37-13:01] What is learned from the comments on these changes [13:02-14:07] Where can listeners go now to get more information?   Links | Resources: JAMA article Click Here Fact Sheet: President Donald J. Trump Announces Actions to Lower Prescription Drug Prices  Click Here Lowering Drug Prices by Once Again Putting Americans First  Click Here   Subscribe Today! Apple Podcasts Amazon Podcasts Spotify Android RSS Feed

The Senate HELP committee report calls for reforms within the 340B drug discount program. Blue Shield of California leaked health data of nearly 5-million members to Google. And, measles misinformation is on the rise nationwide, according to a new poll. That's coming up on today's episode of Gist Healthcare Daily. Hosted on Acast. See acast.com/privacy for more information.

The ancillary outpatient sites known as 340B child sites serve as important places for patients to access the drugs and care they need. There are crucial steps involved in effectively onboarding potential child sites as well as ongoing processes involved with maintaining the parent hospital's partnership with those sites. University Hospitals Cleveland Medical Center  340B Pharmacy Manager Joe Moss joins us to shed light on this process and the potential problems to be on the lookout for.How is a 340B child site onboarded?Moss says the first big step to identifying potential sites is to work with a hospital's finance, revenue, pharmacy, and legal departments to evaluate a site. The team looks at Medicare cost reports and trial balances to ensure they are eligible for 340B. As part of the process, they also use electronic medical record and retail data to identify potential clinic areas based on their patient volumes.A 340B child site is registered. Now what?The work is not over once a child site has been registered in 340B. UH has a program it calls the “340B Concierge Program,” which aims to provide comprehensive, ongoing support and guidance to a given child site. The program offers additional education and information in such areas as procurement processes, the appropriate ways to handle drug transfers, and miscellaneous licensing issues.Onboarding requires relationships and a close eye on complianceMoss says that hospitals onboarding a child site should establish and maintain close ties with the site to prevent issues with 340B compliance. This can involve being the first line for any pharmacy issues the site staff might be having, holding frank conversations with clinic management when necessary, and inviting staff to observe mock audits so they can learn more about what goes into maintaining 340B compliance.Resources:Trump Executive Order Could Revive Medicare 340B Cuts

Send us a textSchedule an Rx AssessmentCracking the 340B code can feel like climbing Mt. Everest…but done right, it can be an absolute game-changer for independent pharmacies. That's what this week's episode of The Bottom Line Pharmacy Podcast is all about! Scotty Sykes, CPA, CFP® and Kathy Blanchard team up with Draven Tell, Lead Analyst at Secure340B to break down:  - Low Hanging Fruits With 340B Programs - Why Accumulators Matter and Their Impact on Your Bottom Line - How state legislation is pushing back against manufacturer restrictions Join the discussion with us!Click here for the transcript. Stay connected with Draven Tell and Secure340B: Draven Tell LinkedInSecure 340B WebsiteSecure 340B FacebookSecure 340B Twitter (X)Secure 340B LinkedInSecure340B InstagramStay connected with us:  FacebookTwitter (X)LinkedIn InstagramScotty Sykes – CPA, CFP LinkedIn Scotty Sykes – CPA, CFP Twitter More resources on this topic: Podcast | Overcoming Challenges with 340B ContractsPodcast | Understanding 340B Contracts and Maximizing Your Pharmacy's BenefitsClip | The Impact of DIR Fees on 340B Pharmacies

In this episode of the Pharmacy Innovators Podcast, host Jim Jorgenson is joined by two powerhouse voices in the 340B space: Kristin Fox Smith, Visante's own 340B expert, and Ted Slafsky, Publisher & CEO of the 340B Report. Together, they dive into the latest political and regulatory shifts shaking the 340B landscape — from new Congressional leadership and pending legislation to the major reorganization of HHS and HRSA. The episode also explores Medicaid trends, judicial developments, contract pharmacy access, and the broader political forces shaping healthcare access for vulnerable populations. Whether you're a healthcare leader, policymaker, or 340B stakeholder, this episode offers timely and valuable insights into the evolving landscape of the program. 340B Report website: https://340breport.com/ Subscribe now using coupon code VISANTE25

In this episode of Product in Healthtech, we reconnect with Scott Martin, founder and CEO of Rescription, to discover how his company has evolved since our previous conversation.Topics covered:Rescription's "radical clarity" approach to transforming prescription drug costsHow Rescription leverages the 340B federal program as intended to benefit both health systems and patientsResults from partnerships with Bergen New Bridge and Baton Rouge General, showing 27-35% savingsWhy patients under Rescription's model receive zero-dollar copays for prescriptionsThe patent-pending adjudication technology developed with Vynyl that enables upfront processing at scaleRescription's ambitious expansion plans across 14 states and 15 additional health systemsKey moments:[01:16] Scott explains how Rescription's model differs from traditional PBMs[03:09] Clarifying misconceptions about the 340B program[05:14] Updates on partnerships with Bergen New Bridge and Baton Rouge General[07:25] How Rescription addresses pharmaceutical manufacturer pushback[09:24] Details on Rescription's patent-pending adjudication technology[11:15] Future expansion plans and new service offeringsResources mentioned:Wall Street Journal article featuring Rescription (link to be added)Follow Product in Healthtech:Website: productinhealthtech.comLinkedIn: Product in HealthtechEmail: info@productinhealthtech.com Product in Healthtech is community for healthtech product leaders, by product leaders. For more information, and to sign up for our free webinars, visit www.productinhealthtech.com.

In this week's episode, Greg and Rob are joined by colleague Heidi Larson to recap lots of questions that came out of a recent SpendMend webinar focused on 340B location issues. They'll address issues like what is considered onsite vs. offsite for the purposes of OPAIS registration, when newly registered locations are eligible to use 340B and a variety of other issues pertaining to how entities need to address their locations from a 340B compliance perspective. In the intro, the guys catch up on 340B hot topics in the news. They'll hit highlights of lots of state level activity, discuss ongoing changes in D.C. with federal agency changes, and a new White House executive order with some 340B implications. If you missed the webinar, you can catch it again on demand here: https://ww2.spendmend.com/webinar-all-about-locations-understanding-the-importance-of-location-considerations-in-340b-program-compliance/ If you have any question or topics to suggest, email us at 340BUnscripted@spendmend.com

In this episode, Alan Condon, Editor-in-Chief at Becker's Healthcare, dives into the latest federal policy shifts impacting the 340B drug pricing program and highlights a major acquisition move by Ascension Health.

This podcast will provide members with an analysis of the Trump Administration's Executive Order (EO) on drug pricing. We'll talk through what the EO means for the 340B program, the Inflation Reduction Act's negotiated drug pricing program, and site neutral payment, and what ASHP will be watching in the coming weeks.  The information presented during the podcast reflects solely the opinions of the presenter. The information and materials are not, and are not intended as, a comprehensive source of drug information on this topic. The contents of the podcast have not been reviewed by ASHP, and should neither be interpreted as the official policies of ASHP, nor an endorsement of any product(s), nor should they be considered as a substitute for the professional judgment of the pharmacist or physician.

Joe Grogan sits down with Dr. Anthony DiGiorgio, a neurosurgeon and health policy researcher, for a wide-ranging conversation on the challenges facing America's healthcare system. Drawing on his experience at a safety net hospital, Dr. DiGiorgio discusses the realities of trauma care, including the treatment of traumatic brain and spinal cord injuries, and the systemic issues within Medicaid that hinder access and quality of care. The conversation also explores the misuse of the 340B program, the ethics and logistics of overlapping surgeries, and the growing crisis of physician burnout. Dr. DiGiorgio shares his advocacy for direct primary care and the promise of AI as tools to reduce administrative burdens and improve patient outcomes.

Health care executive Gavin Magaha discusses his article "Advancing drug discount programs starts with collaboration and clarity." He outlines how the 340B drug discount program, established over 30 years ago, has not evolved with modern health care delivery, leading to complexity, poorly defined standards, compliance issues, and misaligned incentives that hinder its original intent to serve vulnerable patients. Gavin highlights challenges like the outdated package-based discount model, the use of unapproved replenishment methods, and a lack of data transparency contributing to disproportionate program growth—a 23 percent increase in 340B sales versus an 11.4 percent rise in total U.S. drug spending in 2023. The solution, he argues, lies in stakeholder collaboration unified by advanced technology: centralizing data, leveraging analytics and machine learning for transparency and compliance, and creating a single source of truth to foster trust, reduce costs, and ensure the program effectively supports patients. Our presenting sponsor is Microsoft Dragon Copilot. Microsoft Dragon Copilot, your AI assistant for clinical workflow, is transforming how clinicians work. Now you can streamline and customize documentation, surface information right at the point of care, and automate tasks with just a click. Part of Microsoft Cloud for Healthcare, Dragon Copilot offers an extensible AI workspace and a single, integrated platform to help unlock new levels of efficiency. Plus, it's backed by a proven track record and decades of clinical expertise—and it's built on a foundation of trust. It's time to ease your administrative burdens and stay focused on what matters most with Dragon Copilot, your AI assistant for clinical workflow. VISIT SPONSOR → https://aka.ms/kevinmd SUBSCRIBE TO THE PODCAST → https://www.kevinmd.com/podcast RECOMMENDED BY KEVINMD → https://www.kevinmd.com/recommended

Charlton Park, CFO and Chief Analytics Officer at University of Utah Health, explores the trends the organization is focused on, including AI and automation efforts like AI scribe solutions and streamlining business processes. He also addresses ongoing challenges with payers and the complexities of the 340B drug pricing program. Park outlines how Utah Health is tackling the growing demand for services through a comprehensive growth plan, including the launch of the ambitious "West Valley City Project."

Health Resources & Services Administration (HRSA) audits of hospitals play a key role in ensuring compliance with 340B rules and regulations. In this episode, Dave Lacknauth, executive director of pharmacy services at Broward Health in Fort. Lauderdale, Fla., joins us to discuss the importance of taking a proactive, comprehensive approach to audit readiness with the goal of ensuring clean audit results. Compliance protects 340B accessBeing prepared for HRSA audits serves a crucial function that ultimately benefits the patients whom hospitals serve, Lacknauth explains. Maintaining the integrity of 340B means protecting access to 340B savings that hospitals can invest in crucial care for community members that need it. Continuous audit readinessLacknauth discusses how Broward Health maintains audit readiness by conducting internal audits, bringing in external consultants, and identifying areas of opportunity for improvement. A robust system of internal reviews means that when HRSA comes knocking, Broward Health is already prepared. This was evident after a recent audit of one of the system's hospitals that resulted in zero recommendations for improvement.Organization, resources, transparency are keyPreparing for audits requires a health system to invest time and resources, but Lacknauth stresses that these investments pay off. Engaging a comprehensive team from various departments in the audit readiness process allows for a health system to have the appropriate level of responsiveness and transparency during a HRSA audit.Resources:Nebraska Is 12th State To Enact Contract Pharmacy ProtectionsIdaho Becomes Fourth State To Mandate 340B Reports From Hospitals

In this episode of DC EKG, policy expert Ryan Long unpacks the tangled evolution of the 340B program—from its origins in the early 1990s to its explosive, unintended role in today's healthcare market. Originally designed to help hospitals serving the uninsured access affordable drugs, 340B has morphed into a tool for profit, driving hospital consolidation, inflating costs, and straining the biotech innovation ecosystem. Ryan explains how vague eligibility rules, lack of oversight, and policy loopholes have turned a small support program into a massive $54 billion industry—with no requirement that savings actually reach the patients it's meant to help. This is a must-listen for anyone interested in how drug pricing policy, hospital behavior, and innovation incentives are shaping the future of medicine in America.

Hospitals' access to a federal drug discount program will be strengthened under a bill passed in the Nebraska Legislature Thursday. The 340B program requires drug companies to provide discounts to certain hospitals in exchange for their participation in Medicare and Medicaid. In recent years, some drug companies have placed data reporting requirements on hospitals and restricted which pharmacies they can use to distribute the discounted drugs. A bill from Sen. Brian Hardin prohibits these restrictions.

On this edition of Inside the 1581, we'll be discussing the 340B drug discount program and its essential role in strengthening the healthcare safety net, especially in rural areas. Trent Bourland, CEO of Coal County General Hospital, and Jay Johnson, president and CEO of DRH Health, Duncan, join us to talk about the 340B program, its impact on hospitals and healthcare providers, and how it affects patients, especially those who rely on it for access to the healthcare they need. We also discuss House Bill 2048, the 340B protection bill now moving through the Oklahoma Legislature.www.insidethe1581.com

Artificial intelligence continues to impact industries, including pharmacy and 340B. As hospitals and health systems consider adopting AI, we spoke with Kristin Chupka, the 340B program system director for Dartmouth Health, who shares her experience launching this initiative there and considerations for entities seeking to do the same.  AI, automation, and how they can support 340BChupka distinguishes that AI is like a machine learning and making decisions depending on what it is taught. Automation, although similar to AI, does not make decisions. Both can systematize processes and with the help of guardrails, enable pharmacists to dedicate more time to patient care. Opportunities and considerations The novelty of AI promises an opportunity for 340B teams that can consider and correct its potential pitfalls. Chupka explains that as with any emerging technology, it is best to start slowly, teach the algorithm, and consistently check in to ensure accuracy and ethical considerations. This approach can limit errors and inspire confidence as time goes on. What entities can learn from Dartmouth Health? The Dartmouth Health team has explored how AI can help with budgeting, modeling, and auditing, always double-checking work to avoid errors. Because a fully staffed team is required for this, Chupka reassures that AI has not affected staffing. If anything, Chupka says AI is a tool to assist in compliance. Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you'd like us to cover in this podcast, email us at podcast@340bhealth.org. Resources:340B Health, Member Hospitals Ask Court To Throw Out Drugmaker Rebate Lawsuits)

In this episode, Greg and Rob are joined by Meetali Desai, a pharmacy business leader for a large health system in New England, to discuss thoughts around projecting the impact that IRA-mandated Medicare drug prices will have on 340B covered entities, which will go into effect in January 2026. Meetali shares her approach to quantifying the impact a 340B provider might feel from the intersection between these two federal programs. She'll also offer her insights into other hot topics in the 340B space. In the intro, the guys will discuss updates in the news, including movement in current litigation between HHS and manufacturers attempting to implement 340B rebate models, as well as some concerns regarding cybersecurity risks in the vendor-space. Email us your questions and topics recommendations – 340BUnscripted@spendmend.com  

Hospital clinical pharmacies play a key role in ensuring patients are taking medications effectively and supporting other providers who are managing their care. Mark Riggle, the assistant chief pharmacy officer at UC Davis Health, explains how 340B helps make this direct care and ancillary support possible.Clinical pharmacies are a bridge between providers and patientsRiggle says clinical pharmacy teams serve as drug experts that can help teach patients about potential side effects and how to take their medications properly. But these teams also can take the lead on supporting other providers on refills, prior authorizations, financial assistance, and more. That allows the other providers to focus less on those processes and more on providing medical care to the patients. In-house pharmacies can improve patient care and generate revenueUsing an in-house clinical pharmacy has benefits for both patients and the hospital. Riggle notes that keeping prescriptions and pharmacy support in-house can enable hospitals to keep better track of patients' health and identify if there are issues or questions with certain medications. At the same time, it generates revenue and 340B savings that support even more hospital services and improve patient health outcomes even more.Ramping up clinical pharmacy services and overcoming barriers can take timeRiggle says expanding clinical pharmacy initiatives at UC Davis Health has come with some challenges. It took years to roll out a refill program for all the providers who needed that support, and achieving success with a prior authorization program involved an evaluation of workflows to improve efficiency. But he noted that hospital pharmacists can present a value proposition to their leaders for how investing in 340B-supported clinical pharmacy services can be worth it to improve care quality and provider satisfaction.ResourcesFederal Judge Allows 340B Health, Member Hospitals To Intervene in Rebate Lawsuits

In this week's episode, Greg and Rob recap lessons learned from the recent 340B Coalition Winter Conference in San Diego. They'll share commentary that was circulating regarding HRSA audit trends, 340B rebate models, Inflation Reduction Act impact on budgets, contract pharmacy developments and some insights on what to watch for out of Washington D.C. Email us your questions at 340BUnscripted@spendmend.com!

In this episode of Generous Impact, hosts Bret and Amanda Brummitt are joined by Jose Ferrua, Vice President of Finance and Business Development at Lone Star Circle of Care. Discover how this Texas-based organization provides healthcare to over 100,000 patients annually, regardless of their financial situation. Jose shares insights from his journey from the Dominican Republic to becoming a healthcare leader at Lone Star Circle of Care, highlighting his commitment to eliminating health inequities and expanding access to care. Dive into Lone Star's initiatives, such as their innovative mobile mammogram bus and the expansion of the 340B drug program, designed to lower medication costs for patients. Learn about the organization's vision to bridge healthcare gaps, providing quality and affordable care to all. This episode also touches on the importance of partnerships, community involvement, and continuous improvement in the healthcare sector.

Murphy explores the intersection between humor and female rage in NOTES ON SURVIVING THE FIRE, a page turner that doesn't blink at themes of sexual violence and how society (academia in this case) dismisses survivors.

Special guest host Tres Watson with Capitol Reins PR and Kentucky Politics Weekly fills in for Kruser as he talks with Dr. Charles Courtemanche from UK Gatton School of business about 340B and Medicare in Kentucky and Rep. Jason Nemes about the State Legislative session in hour 2. See omnystudio.com/listener for privacy information.

On this episode, Rob and Greg are joined again by healthcare attorney Emily Cook. Emily shares some insight into CMS Provider Based Rules and how 340B covered entities need to be thoughtful about where these rules intersect with various 340B Program initiatives, including new outpatient service implementation, referral capture and pharmacist-driven medication management models. We are at 340B Coalition Winter Conference in San Diego, CA. Come visit us at booth #315 to talk with our team about hot topics in the 340B world, from patient definition to HRSA audits, to program optimization!

The legal fight over drugmakers' push to impose 340B rebates is heating up, with five lawsuits pending in a federal court in Washington, D.C. Recently, 340B Health joined with two of its member hospitals in asking the court to intervene as defendants to stop these rebates from taking effect. Genesis HealthCare System based in Ohio is one of those hospitals. Shona Carr, the director of 340B and ambulatory pharmacies at Genesis, breaks down how rebate models would create financial challenges for hospitals that would hamper their patient care initiatives.Carrying and Compliance CostsEach drugmaker's push to impose rebates would incur new drug purchasing and compliance expenses for covered entities. Bristol-Myers Squibb's rebate policy alone would cost Genesis HealthCare System an additional $400,000 per month in drug spend if it applied to all BMS drugs. If 340B rebate models became the norm for all drugmakers, Carr estimates Genesis would pay an additional $5.2 million per month in upfront costs. Those figures do not include additional hundreds of thousands of dollars in annual staffing expenses to process rebate claims and challenge denials.Effects on Patient Care and SupportImposing 340B rebates could force Genesis HealthCare System to scale back or discontinue its patient assistance program, according to Carr. But 340B savings do not just go towards direct patient help with drug costs at the hospital. The financial impact of rebates also could affect other community programs and free services, such as patient transportation, meds-to-beds, health screenings, and a paramedicine program.Advice for Other HospitalsCarr says every covered entity that has not already done so should begin reviewing drugmaker rebate policies and working with their 340B third-party administrators to estimate potential costs. She says this involves entities asking bigger questions: Would rebate policies require additional 340B staffing? Does senior leadership understand the potential impact of these changes? What 340B-funded programs might be at risk?Resources:340B Health Seeks To Intervene in All Drugmaker Rebate LawsuitsDeclaration of Shona Carr in Support of Motion To Intervene

Join Bret and Amanda Brummitt in this inspiring episode of Generous Impact as they sit down with Matt Vestal, co-founder of Junction Health. Discover how Junction Health is making a significant difference in the healthcare landscape by establishing infusion centers within Federally Qualified Health Centers. These centers aim to provide much-needed life-promoting infusions to patients who face financial barriers in accessing traditional healthcare models. Matt Vestal shares his professional journey, starting from his early career at Cerner to co-founding Junction Health dedicated to serving underserved communities. Dive deep into the challenges and triumphs of operating infusion centers, the importance of the 340B pharmacy program, and how Junction Health is successfully partnering with federally qualified health centers to address healthcare access constraints. Listen in to hear stories that depict the real-life impacts of Junction Health's innovative approach, which not only delivers critical medications to patients in need but also injects vital revenue into health centers that serves the community. Discover the collaborative and compassionate culture fostered by Junction Health's team, determined to bring meaningful change to the world of healthcare. Learn more at Junction-Health.com.  

In this episode, Greg and Rob are joined again by Jeff Davis, healthcare attorney, to catch up on various court action impacting the 340B community. With so many 340B Program elements hung up in litigation, it's challenge to keep tabs on what has been happening. Jeff will recap key appellate court decisions on manufacturer-implemented restrictions of contract pharmacies, discuss the merits of litigation challenging state legislative efforts to protect contract pharmacy provisions, and share opinions on where 340B rebate models may go in the future. They'll also dive in to child site eligibility timing, HRSA-approved manufacturer, audits and recent threats to covered entities who receive in-kind funding. They'll also debate patient definition standards now that we are a year removed from the Genesis case.  We can't wait to see you at 340B Coalition Winter Conference in San Diego. Catch up with the SpendMend team at Booth #315.   

Nebraska lawmakers considered a bill to strengthen a federal drug discount program this afternoon. Sen. Brian Hardin introduced the 340B Contract Pharmacy Protection Act to help rural hospitals. The 340B program allows certain hospitals and pharmacies to purchase drugs from manufacturers at a reduced cost. In recent years, some pharmaceutical companies restricted pharmacies from accessing the discounted drugs. Hardin said his bill would prohibit these companies from interfering with drug delivery.

In this week's episode, Greg and Rob catch up on newsworthy developments in the 340B community. They'll discuss various state and federal legislative developments, they'll share how recent White House executive orders, including a pause on federal agency communications and grant funding freezes, may be impacting 340B providers, and they'll offer some commentary on HHS Secretary confirmation hearing debate. Catch us at the 340B Coalition Winter Conference in San Diego, CA! The SpendMend team will be at Booth 315

In what has become an annual tradition for the podcast, we consulted with 340B Health's expert staff to answer our listeners' most pressing 340B questions. As an uncertain and busy year starts for the world of 340B, we want to prepare you by covering your queries about the efforts by drug companies to impose 340B rebates, proposed federal and state legislation on 340B, how Inflation Reduction Act implementation will affect 340B, and more.340B Rebate Lawsuits Heat UpSo far, five drug companies have sued the Health Resources & Services Administration to challenge HRSA's rejections of their backend rebate proposals. 340B Health Vice President of Legal and Policy Amanda Nagrotsky notes that a rebate model would harm 340B hospitals through delayed access to 340B savings and potentially denials of legitimate rebate claims based on drugmaker interpretations of 340B rules. We recorded this episode just before 340B Health filed a motion to intervene as a defendant in the Johnson & Johnson (J&J) rebate lawsuit against HRSA.Lawmakers Eye Ways To Protect or Cut 340BThe new year means a new Congress and the start of new state legislative sessions. 340B Health Senior Vice President of Government Relations Tom O'Donnell notes that members of Congress have floated potential reductions in what the federal government pays for 340B drugs to help fund new spending priorities outside of health care, though it is unclear how seriously they are considering those options. 340B Health Vice President of Legal and Policy Greg Doggett reports that several states are considering new contract pharmacy or payment nondiscrimination protections for 340B hospitals, but others have introduced proposed new mandates for covered entities. Price Caps Will Apply to More Medicare DrugsThe list of drugs eligible for Medicare price caps will grow to 25 starting in 2027 under the Inflation Reduction Act, which will have implications for 340B savings on those drugs. 340B Health Research and Policy Analytics Manager Claudia Escue notes that popular weight loss and diabetes drugs like Ozempic and Wegovy have made the price cap list because of how much they cost Medicare. 340B Health is tracking how these price caps might lower 340B savings and have submitted letters to Medicare officials to represent other hospital concerns about the implementation of the IRA.Resources:340B Health Files Motion To Intervene in J&J Rebate LawsuitOption To Cut Commercial Pay Rates for 340B Drugs Is on Draft Congressional Budget “Menu”Medicare Expands List of Drugs Subject to Price Caps, Decreased 340B Savings340B Coalition Winter Conference Registration 

Hosts: Erin Rider and Guest Host Jason Perry  Pres. Trump addresses the nation following deadly plane crash  It's the most talked-about story today -- the deadly crash in the skies between a regional passenger jet and a military helicopter, resulting in the deaths of more than 60 people. President Trump addressed the nation earlier and confirmed what many had been dreading... that there were no survivors. Inside Sources begins with a discussion on this important national story.   Gabbard, Patel face Senate confirmation hearings  Senate confirmation hearings continued on Capitol Hill today as Senators grill President Trump's nominees about their pasts. Today, Tulsi Gabbard spoke to the Senate Intelligence Committee as part of the process to become the director of national intelligence. Kash Patel, Trump’s pick for FBI director, also faced difficult questions from the Senate Judiciary Committee. The Inside Sources hosts share their big takeaways from the hearings.    On the Hill 2025: Legislation addressing drug pricing  A large PAC is campaigning against a bill currently being discussed on Utah’s Capitol Hill. The bill, SB69: Medication Amendments, is being sponsored by State Senator Evan Vickers. His legislation addresses the 340B drug program, which several large national groups do not like. State Representative Steve Eliason is an expert on the program and knows the bill well; he joins the show to explain.    On the Hill 2025: Legislation proposing Election Day become a state holiday  Our special coverage of Utah's Legislative Session continues with a look at a bill that would designate Election Day as a state holiday. The idea has been floated around the country for years now, and some states actually do have Election Day set aside as a state holiday. Utah is not one of those states, but State Representative Ryan Wilcox hopes to change that. He joins Inside Sources to discuss the motivations behind the bill.    Pres. Trump proposes sending criminal illegal immigrants to Guantanamo Bay  Guantanamo Bay is back in the news today, as President Trump directs the Pentagon and Department of Homeland Security to house criminals set to be deported from the United States. It's part of his plans to crack down on illegal immigration and secure the southern border. Inside Sources host Erin Rider and guest host Jason Perry share their insights into this plan.    Projecting the rise – or possible fall – of the federal deficit under Pres. Trump  As President Trump has taken office and began working on his agenda, one question has been brought up several times, especially by very conservative members of the Republican Party: how will these decisions affect the national debt? Mike Murphy, Senior Vice President at the Committee for a Responsible Federal Budget joined the program before the inauguration; he joins us again to update his predictions.    Pentagon agency pauses celebrations for ‘diversity’ holidays  Federal agencies have been directed to end Diversity, Equity, and Inclusion (DEI) programs. Now, we're getting a better idea and look at how these programs will be discontinued. The Defense Department's intelligence agency recently sent out a memo saying it's pausing observances of diversity-related holidays. Inside Sources looks into the relationship between this move and President Trump’s agenda.    Air taxis moving towards the future in Utah  The future is coming into reality here in Utah, as the plan to launch air taxis moves forward. A new bill in the state legislature makes several propositions to advance air mobility. Inside Sources finishes with a discussion on the future of transportation.   

Hosts: Erin Rider and Guest Host Jason Perry  A large PAC is campaigning against a bill currently being discussed on Utah’s Capitol Hill. The bill, SB69: Medication Amendments, is being sponsored by State Senator Evan Vickers. His legislation addresses the 340B drug program, which several large national groups do not like. State Representative Steve Eliason is an expert on the program and knows the bill well; he joins the show to explain. 

In our first episode of 2025, Greg and Rob discuss the latest developments in 340B. They'll recap HRSA audit trends, discuss how Congressional committee membership seems to be forming, and discuss a variety of 340B provisions being litigated in court.

If you have zero clue what co-pay maximizers and/or co-pay accumulators are and the financial incentives involved for PBMs (pharmacy benefit managers) and plan sponsors here, after you're done listening to this episode, go back and listen to the show with Joey Dizenhouse (EP423). Also, the episode called “Game Theory Gone Wild” with Dea Belazi, PharmD, MPH (EP293). Both these shows could fill in some blanks. For a full transcript of this episode, click here. If you enjoy this podcast, be sure to subscribe to the free weekly newsletter to be a member of the Relentless Tribe. Here's the micro mini of the co-pay maximizer/accumulator deal. These are vehicles that are designed by vendors who are also sometimes called maximizers or sometimes they're also PBMs. But these programs are designed to get as much money out of Pharma as possible in the form of co-pay support. So, here's how the maximizers are supposed to maximize plan sponsors getting pharma money. Say, for some drug, the pharma company has, I don't know, $12,000 max in co-pay support available to patients in total per year. Pharma does always cap the dollars that are available for patients. So, in this hypothetical, $12k a year is available. What a forthright or well-run maximizer will do is figure out, you know, if there's $12k max available, then they'll set a co-pay—so there's variable co-pays for patients—so they'll set a patient co-pay of, like, $1000 a month, which adds up to $12k over 12 months of the year. Get it? Every single month, the patient has a $0 co-pay, but the plan maximizes the dollars that the plan gets. Or, you know, maybe they'll charge $1,025 a month so the patient has some small “skin in the game,” and the plan sponsor just banked $12k. Sounds great, right? Well, sure, when it works as promised … and we'll get to this in a moment. Accumulators, on the other hand, have no such “Hey, let's make sure the patient actually gets their meds” guardrails. They hear that the Pharma is offering $12k, and the accumulator vendor and their plan sponsor clients also are like, “Cool, let's get that money as fast as possible.” So, they make the co-pay for that drug, I don't know, like hypothetically $3000. Great, now the patient runs out of that co-pay money in May. And don't forget and/or let me inform you, for both maximizers and accumulators, dollars paid by the Pharma generally don't count to the plan deductible for the patient. So now, the patient walks into the pharmacy, if in an accumulator or in a poorly run maximizer program, they walk into the pharmacy in May and are told that if they want their drug, they're gonna need to pay the $3000 co-pay that was set out of pocket every month until they reach their deductible. With some of these co-pay maximizer/accumulator plans, the plan sponsor may be a little bit out of the loop relative to what is actually going on here. The plan sponsor may think that members are doing fine—you know, they're getting their drug every month—so they may be surprised to learn about this running out of money in May issue. And what is true more often than it's not true, this $3000 or whatever—hundreds or thousands of dollars—payment due co-pay, the patient learns about it at the pharmacy counter or while trying to get chemo. It comes as a complete surprise, the fact that they owe three grand or whatever. What patient just shrugs and pays up in that moment because they happen to have their entire deductible or thousands of dollars lying around and at the ready? What a shock to find this out at the pharmacy counter or at the infusion clinic. Some of these maximizer programs are also starting to veer back into accumulator zones, like they're doing things such as saying that the member must pay their out-of-pocket max or their deductible or 30% of the cost of the drug, right, like some number before the plan will allow the patient to use the co-pay reimbursement program to begin with. So, there's other things that are emerging right now, which, again, cause the patient to have a very, very large out of pocket in order for them to get a drug which they have been prescribed and—ostensibly, at least—need. Allegedly, and sometimes for sure, dollars raked in from Pharma make it across the PBM/maximizer, vendor, middleman trench all the way over to the plan sponsor. For sure, especially for the administrative only maximizer vendors … yeah, you're gonna have the dollars actually making it to the plan sponsor. But sometimes the vendor running these programs is paid spread, right? So, the more expensive the drug and the richer the co-pay card program, the more the vendor will make because they take a percentage of savings. So, the more expensive, the more savings, therefore, the more the vendor is gonna make. In these cases where the vendor is paid a spread, can I take Perverse Incentives for $600, Alex? Right? But in sum, again, there's a lot to this conversation with Bill Sarraille, so please do listen to the whole thing. Bill offers five main pieces of advice, so I'm just gonna cover them right here up front—spoiler alert, I guess, but just to keep them all in one place. 1. Look into what is going on with a maximizer and/or accumulator program. First of all, is the plan sponsor paying spread? And also, how are these programs being marketed to members and how aggressively? Because there are a lot of plan sponsors having way more negative impact than they suspect they are. So, that's point of advice #1: Really look into actually what is happening on the grounds with some of these programs. 2. Eliminate surprise. Any plan sponsor listening, and Brian Reid also says this very crisply in an episode a month or so ago (EP456). If a plan sponsor wants to do stuff like this—like force a patient to pay hundreds or thousands of dollars out of pocket—if at any point during the year they are gonna wind up with thousands of dollars in co-pay or coinsurance to get their Crohn's disease med or cancer med or whatever, be really up front about this at least. It's really important if we really want to make sure that patients are taking maintenance meds and getting the medications that they're prepared for the reality that, at a certain point during the year, they are going to have a really big bill. 3. There is legal risk here. So also, Bill's advice is check into whether accumulators and/or maximizers are unlawful under the ACA (Affordable Care Act) and/or by deceptive practices rules when maximizers or accumulators are teed up as a benefit. And it, again (reference point of advice #2), it's not explained that dollars they get from Pharma will be taken by the plan and not applied to the patient deductible. I was just reading about the crazy aggressive marketing tactics that some of these vendors are using to get members to sign up and … yeah, definitely look into deceptive practice rules. 4. If it's utilization management that we're trying to achieve here, then your utilization manager should be utilization managing. These maximizers are not meant to impact utilization management. Patients really cannot differentiate, as per study after study, it's very difficult for patients to differentiate high-value from low-value care or meds. So, pretty much the impact of having a patient with thousands or hundreds of dollars of out-of-pocket spend to get a med isn't going to be to ensure that the right people are taking the right med. Point is, use the right tool for the right job. So, if we're trying to keep patients away from low-value meds, the tool for that is utilization management. Also be aware, if the PBM says it cannot do utilization management or you'll lose your rebates and/or is pushing into a maximizer accumulator program to do this instead, that's kind of a clue that they cannot do it because they are taking money from Pharma to not have any restrictions on a drug. Read the article in the New York Times (you're welcome) about how PBMs took secret payments for the free flow of opioids, and Chris Crawford also talks about this sort of same-ish thing in an upcoming show relative to GLP-1s. But if you're trying to do utilization management, then do utilization management. 5. Use our understanding of this whole goings-on as a rationale or a way to tamp down perverse incentives. We want to wind up with patients getting charged a percentage of net prices, not a percentage of some wildly inflated list price with this whole accumulator maximizer contributing to, you know, just more wildly inflated list prices so the co-pay programs can be bigger and someone can make even more money off of the percentage of savings. And plan sponsors addicted to rebates now have another bucket of cash. Like, this is just another example of how perverse incentives pervade the system. And we should certainly be aware of that. Bill Sarraille was a healthcare attorney for many years. He retired from his law firm on the first of last year, and now he's doing the things he wanted to do before but couldn't because his billable rate was too high. Bill is teaching at the University of Maryland Law School and doing some regulatory consulting, etc. He's working with a variety of patient groups. Also mentioned in this episode are University of Maryland Francis King Carey School of Law; Joey Dizenhouse; Dea Belazi, PharmD, MPH; Brian Reid; Chris Crawford; Marilyn Bartlett; Scott Haas; Paul Holmes; and Tom Nash. You can learn more at University of Maryland Francis King Carey School of Law and by following Bill on LinkedIn. You can also sign up for his Substack.   Bill Sarraille is a professor of practice at the University of Maryland Francis King Carey School of Law, a regulatory consultant, and a retired senior member of the Healthcare Practice group at Sidley Austin LLP. Bill is a nationally recognized expert in healthcare, life sciences, drugs, medical devices, and patient access to treatments. He is widely known for his expertise in a broad array of healthcare matters, including rare disease treatment access barriers, pharmaceutical pricing, Anti-Kickback Law compliance, the 340B program, and managed care and PBM issues. During his years practicing law, Bill was recognized repeatedly by The Best Lawyers in America in both healthcare law and administrative law. He was also consistently listed as a leader in the field of healthcare law in Chambers USA: America's Leading Lawyers for Business. Bill also serves as the general counsel of the charity the Pharmaceutical Coalition for Patient Access, as an advisor to multiple patient advocacy groups on patient access issues, a compliance advisor to a coinsurance patient assistance foundation, and as the director of a rare disease society and Kalderos, Inc., a health IT firm with a focus on effectuating pharmaceutical discounts and rebates.   09:31 What should plan sponsors be aware of right now? 14:01 What is the justification for maximizers, and why is this at odds with the purpose of insurance? 18:05 Where does the issue of “fairness” land within cost containment? 20:00 Brian Reid's LinkedIn post on insurance company access challenges. 21:30 What are the real legal issues presented by some of these co-pay maximizers and co-pay accumulator programs? 27:06 How are these programs creating perverse incentives? 29:28 EP450 with Marilyn Bartlett, CPA, CGMA, CMA, CFM. 32:16 “If you're covered by the ACA, I think this is unlawful.” 32:57 What advice does Bill have in regard to these programs? 33:49 What potential litigations does Bill see coming in the near future in regard to these co-pay maximizers and co-pay accumulator programs? 38:38 EP365 with Scott Haas. 38:45 EP397 with Paul Holmes.   You can learn more at University of Maryland Francis King Carey School of Law and by following Bill on LinkedIn. You can also sign up for his Substack.   @HCLAWComment discusses #costcontainment on our #healthcarepodcast. #healthcare #podcast #pharma #healthcareleadership #healthcaretransformation #healthcareinnovation   Recent past interviews: Click a guest's name for their latest RHV episode! Stacey Richter (INBW41), Andreas Mang (Encore! EP419), Dr Komal Bajaj, Cynthia Fisher, Stacey Richter (INBW40), Mark Cuban and Ferrin Williams (Encore! EP418), Rob Andrews (Encore! EP415), Brian Reid, Dr Beau Raymond, Brendan Keeler