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SNHPA Publishes More Chapters of New Survival Kit
SNHPA has published two new chapters of its 340B Survival Kit, a comprehensive and valuable resource on the 340B program that helps SNHPA members comply with federal law while maximizing discounts. Because most disproportionate share hospitals (DSH) operate within health systems comprised of multiple providers and facilities, identifying a DSH hospital’s scope to determine which facilities are eligible for 340B discounts can be difficult. Moreover, under its proposed patient definition guidelines, the Health Resources and Services Administration (HRSA) may change the standard for determining whether a facility is regarded as part of a 340B hospital. Chapter 3 reviews the current standard of eligibility and explores the potential implications of the revised standard under HRSA’s proposed guidelines.
340B hospitals also face the challenge of buying and tracking different drug inventories for use in “mixed-use” settings where 340B-eligible and 340B-ineligible patients are treated. These settings involve the provision of inpatient and outpatient services, but only outpatients are currently eligible to receive 340B drugs except in cases where a hospital has been able to obtain 340B pricing voluntarily from a drug company. Consequently, 340B hospitals must establish inventory management systems to avoid providing 340B drugs to ineligible (i.e. inpatient) recipients while also ensuring that drugs purchased at 340B discounts are not dispensed to non-340B patients. Chapter 8 reviews the federal standards governing inventory management practices and the application of those standards to 340B hospitals and should be very helpful to your hospital as it reviews its compliance practices.
The 340B Survival Kit is a member only benefit. If you are a member, you can view these chapters (Chapters 3 and 8) in the “Members Only” section of SNHPA’s website at: http://www.safetynetrx.org/members/340B_survival_kit.cfm. More chapters will be released as soon as possible.
If you are not a member, you can preview chapters 1 and 2 of the 340B Survival Kit at: http://www.safetynetrx.org/public/340B_survival_kit.cfm. More information on membership benefits and how to apply for membership can be found at http://www.safetynetrx.org/public/mbrs_info.cfm.
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Washington, DC 20005 
