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CMS 340B Hospital Drug Cost Survey Due May 15, 2020

The White House Office of Management and Budget (OMB) approved the Centers for Medicare & Medicaid Services’ (CMS) plan, proposed September 30, 2019, to survey 340B hospitals for their net costs for 340B-purchased drugs billed to Medicare Part B, including sub-340B ceiling price discounts and 340B penny prices.

CMS announced the final survey requirement on its hospital outpatient prospective payment system (OPPS) website: “340B Survey Now Available through May, 15th 2020.” A revised survey instruction sheet found on the webpage says the response period is April 24, 2020 through May 15, 2020 and is accessible here under the hyperlink at the bottom titled, “340B Survey and Instructions.” Download the PDF instructions outlining the necessary requirements and steps to complete the survey.

According to the new instruction sheet, the survey is of a hospital’s “average acquisition costs for specified covered 340B outpatient drugs” bought by the hospital during the fourth quarter of 2018 and the first quarter of 2019. CMS also indicates the purpose of this survey is to obtain results to be used in part to evaluate the average acquisition costs for specified covered outpatient drugs (SCODs) purchased by hospitals under the 340B Program and could be used in settling the appeals challenging the reduction in drug reimbursement rates for 340B hospitals.

Who should fill out this form?

Hospitals purchasing drugs through the 340B Program and enrolled in the 340B program as a covered entity, excluding Critical Access Hospitals (CAHs), in the last quarter of 2018 and/or the first quarter of 2019 are required to complete the survey.

What information is requested?

For each applicable hospital, the survey shall reflect the net acquisition cost for each SCOD acquired under the 340B Program (that is, the sub-ceiling price after all applicable discounts). Acquisition cost refers to the price a hospital pays upon receiving the product (that is, the sub-ceiling price after all applicable discounts); this includes, but is not limited to, 340B drugs purchased via a replenishment model under the 340B Program, or under penny pricing. Applicable discounts are any discounts below the discounted ceiling price. The 340B drug acquisition cost should be reported regardless of whether or not the drug was dispensed at all, or whether the drug was dispensed in multiple settings.

To complete the survey, a hospital must log into its 340B Drug Survey Gateway at https://www.340bsurvey.com/survey and decide which of two methods available to complete the survey:

Please note, only the Detailed Survey OR the Quick Survey needs to be completed.

1.) Detailed Survey: Please use this option to provide the acquisition costs for each individual SCOD.

OR

2.) Quick Survey: Please use this option to indicate the preference for CMS to utilize the 340B ceiling prices obtained from Health Resources and Services Administration (HRSA) as reflective of hospital acquisition costs. After selecting this option, the survey is complete.

If the detailed survey method is selected, a hospital will be required to complete the spreadsheet entitled “Survey Worksheet” following the instructions provided. Information requested by CMS, some of which may be prepopulated, includes HCPCS drug codes, drug names, and descriptions, drug doses, Q4 2018 and Q1 2019 drug payment rates, and average acquisition drugs costs for Q4 2018 and Q1 2019.

The 340B Team at Blue & Co. continues to monitor all changes and guidance provided by CMS, HRSA, OPAIS and other agencies impacting the 340B Program. We are available to answer questions, provide additional guidance and assistance pertaining to this survey request by CMS. Please contact one of our Apexus Certified 340B Experts if you would like assistance.

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