Jason Reddish and Mark Ogunsusi on 340B Drug Pricing Program Compliance [Podcast]


By Adam Turteltaub

The 340B Drug Pricing Program was created to protect safety net hospitals from rising drug prices. It allows them to purchase outpatient drugs, and pharma companies to sell those drugs, at a discount.

In this podcast, Jason Reddish (LinkedIn), Principal and Mark Ogunsusi (LinkedIn), Associate, at Powers Pyles Sutter & Verville provide an overview of the program and the compliance requirements. They are also two of the authors of the chapter “Pharmacy:  340B Drug Pricing Program” in the Complete Healthcare Compliance Manual.

The 340B program helps hospitals that are the last line of defense for underserved communities, including those with a large percentage of Medicaid patients. Often, they are the only hospital around in rural areas. Also helped by the program are federal grantees such as Ryan White clinics and those providing treatment for STDs.

The program dictates which entities can buy discounted drugs and have very specific requirements including two very important ones. First, the drugs cannot be resold or transferred to anyone who is not a patient of the covered entity. Second, double billing of Medicaid is prohibited and must be monitored for.

There are a number of typical compliance problem areas, but the good news is that there has been a decline in non-compliance.

Listen in to learn more about what covered entities are doing right, and what you should be on the lookout for.