In a recent article, Eugenia Pierson, a Principal in Squire Patton Boggs Public Policy Health Care Practice, urged providers to prepare for HRSA’s promulgation of the 340B mega rule. In addition to safety net hospitals struggling with ACA implementation, tight state budgets, and delivery system reform, 340B issues and anticipated program changes promise to be another complicating factor with strong potential to restrict the program and the millions of dollars in savings hospitals and clinics are currently receiving. Her article discusses several key issues that the 340B mega rule is contemplated to resolve. She hypothesizes the upcoming 340B mega rule will resolve: (1) the definitions of eligible patient and covered entity; (2) diversion issues; (3) contract pharmacy compliance; (4) limits on 340B revenue; and (5) shift the focus to the patient.
