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BIO Letter to HRSA on 340B Rebate Model

October 10, 2024

Under the 340B program, participating manufacturers must offer 340B pricing on their covered outpatient drugs by covered entities, as a condition of having those drugs federally payable under Medicare Part B and Medicaid. Critically, Congress established that several conditions of compliance must be satisfied for a provider to access 340B pricing. Among other things, if a participating provider is out of compliance with either the statutory prohibition on Medicaid rebate-340B discounting duplication (hereinafter, “Medicaid-340B duplication”) or the statutory prohibition on diversion, it is no longer a “covered entity” eligible for 340B pricing. There is also no obligation to offer 340B pricing multiple times on the same unit.

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BIO Letter to HRSA on 340B Rebate Model
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In response to the 340B Request for Information issued by the Senate 340B Bipartisan Working Group, BIO submits detailed comments.
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