Great news for 340B Hospitals affected by COVID-19. On March 15, 2022, President Biden signed into law the $1.5 trillion Consolidated Appropriations Acts, 2022.
This bill allows Hospitals that have lost eligibility due to a decrease in their Medicare disproportionate share (DSH) percentage as a result of the COVID-19 public health emergency to regain access to 340B discounts. This does not include any retrospective eligibility and is only temporary. Depending on the fiscal year end of the Hospital, this relief could cover multiple calendar years.
How to Tell if Your Organization Qualifies
As a 340B Hospital affected by COVID-19, the following stipulations must be met to qualify for relief:
- The Hospital must have been eligible for the 340B program prior to the COVID-19 public health emergency (January 31, 2020).
- The Hospital must have lost eligibility during the Medicare cost reporting periods of 2020, 2021, and/or ending December 31, 2022.
- The Hospital must otherwise meet the requirements of being a covered entity and is compliant with all other components of the 340B Program.
- The Hospital must attest to the HHS Secretary the loss of 340B eligibility was the result of the impact to the Hospital in response to or because of the COVID-19 public health emergency.
- This impact resulted in a drop in DSH percentage below the participation minimum percentage requirement.
If you have any questions regarding your Hospital’s ability to take advantage of this opportunity or any other issues related to the 340B Program, please contact one of our Apexus certified 340B experts or your local Blue & Co. Advisor.
Kyle Smith, CPA, Director
Jason Prokopik, PharmD, Manager
Chad Downing, RPh, Senior Consultant