CHA has submitted comments on the proposed remedy issued by the Centers for Medicare & Medicaid Services (CMS) for its 340B-acquired drug payment policy that was in effect from 2018-2022 for hospitals paid under the outpatient prospective payment system.
In the letter, CHA greatly appreciates the proposal to repay hospitals in a lump sum and to include the incremental beneficiary cost sharing in that payment but does not share the belief that this repayment must be done in a budget-neutral manner. CHA believes that the agency should repay hospitals with interest. CHA also encourages CMS to repay eligible hospitals for amounts owed for 340B drugs provided to Medicare Advantage beneficiaries.
CHA thanks members for their input, which helped inform comments.