The policy shifts pharmacy leaders say are most urgent

Pharmacy leaders at health systems across the country say preserving the intent of the federal 340B drug pricing program and increasing transparency around pharmacy benefit managers are the most urgent policy changes that could impact patient access. 

Here are responses from three supply leaders who were asked: What policy or regulatory change would make the most positive impact on your health system’s pharmacy operations in the next year? 

Note: Responses were lightly edited for clarity and length.

Jennifer Bair, PharmD. Vice President of Pharmacy Services and Chief Pharmacy Officer at Prisma Health (Columbia, S.C.): The first is a policy to protect the original intent of the 340B program. My organization has 19 acute care and specialty hospitals, five of which are covered entities under the 340B program. Four of those qualify as disproportionate share hospitals, and one as a sole community hospital. Many of our hospitals and clinics are in very rural areas of South Carolina, where access to care is challenging. Additionally, our population is made up of a significant portion of uninsured and underinsured patients. The 340B program has allowed us to save on qualifying purchases for medications used on outpatients in our system, and those savings have been reinvested back into our patients through programs such as 24-hour retail pharmacy services in rural SC, medication assistance programs (retail pharmacy, specialty pharmacy, and infusion), vaccine clinics, and other important community programs. With the many changes that could potentially affect the 340B program such as maximum fair pricing of medications in the IRA, the 340B rebate model, and payer restrictions on the use of 340B medications, many of these important programs for our community are at risk.

The second is a policy around pharmacy benefit manager transparency. As a self-insured organization who uses a PBM to manage the pharmacy benefits for our team members, there is a need to have full transparency of data to make informed decisions that ensure the best care for our team members and minimize financial risk for our organization.

Tim Lynch, PharmD. Senior Vice President and Chief Administrative Officer at MultiCare Health System (Tacoma, Wash.): Elimination of the proposed 340B rebate pilot program recently announced by the Health Resources and Services Administration to permit select drug manufacturers to replace up-front 340B discounts with back-end rebates for the 10 drugs designated for negotiation under the Inflation Reduction Act will create significant challenges for 340B-covered entities and maintaining the current discount program is critical. Under the proposed model, instead of purchasing these drugs at 340B discounted prices, CEs would be required to pay full price and submit rebate claims data to drugmakers to receive rebates — essentially floating the upfront higher cost of medications pending payment and creating potential cash flow challenges. While the proposal prohibits manufacturers from denying rebates based on diversion or Medicaid duplicate discount concerns, it still allows other scenarios in which rebates could be withheld. There are also significant complexities related to the claims data submission process requiring heavy coordination with information technology and data compliance personnel, that will impose financial and administrative burdens on CEs and reduce already limited resources to serve vulnerable patients. Most concerning, HRSA’s proposal could pave the way for a broader shift to 340B rebate models, as the agency says it may expand the list of drugs following its evaluation of the pilot program. 

Jeffrey Oliver, PharmD. Vice President and Chief Pharmacy Officer at Orlando Health: The biggest legislative change, albeit unlikely, that would positively impact our pharmacy operations would be the introduction and passage of a national pharmacy network access and PBM contracting policy to create a national any willing provider law.

This national legislation could be built using the framework of expanding state level legislation and would require that all retail and specialty pharmacies be afforded fair and lawful access to Pharmacy Benefit Manager networks in accordance with this new federal law.

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