This post has been archived and contains information that may be out of date.
| Action needed: | CHA urges hospital executives to submit comments to the Health Resources and Services Administration (HRSA) on the 340B Drug Pricing Program Omnibus Guidance. Comments can be submitted at www.regulations.gov by searching for Regulatory Information Number (RIN) 0906–AB08, or by email at 340BGuidelines@hrsa.gov, including RIN 0906–AB08 in the subject line of the message. |
| Timing: | Submit comments before 2 p.m. (PT) Oct. 27. |
CHA has prepared the attached comment letter on the 340B Drug Pricing Program Omnibus Guidance, published Aug. 28 by HRSA. In the letter, CHA urges HRSA to consider several important changes to the proposed guidance so hospitals can continue to stretch scarce federal resources as far as possible to provide necessary access to the most vulnerable populations.
Specifically, CHA urges HRSA to change the proposed definition of an eligible patient and an eligible drug; accept alternative forms of documentation to show that a clinic is an integral part of the hospital; reduce the burdensome audit requirements associated with contract pharmacy arrangements; and limit all disclosures to those that rise to the level of being material.
CHA’s detailed comments are the result of a robust dialogue with CHA member hospitals that participate on the 340B work group. CHA urges members to use the attached comment letter as a model in writing their own comments. CHA also encourages members who have not done so to review the proposed guidance summary.