(May 1, 2020) – Despite strong objections from the American Hospital Association, the Centers for Medicare & Medicaid Services has decided to move forward with its survey of hospitals that participate in the 340B Drug Pricing Program in order to collect actual acquisition costs for specified covered outpatient drugs (SCODs). AHA last month again urged CMS to suspend plans for the survey during the COVID-19 national health emergency to allow hospitals to redirect staff and resources in their response to the COVID-19 patient surge. However, the agency has ignored these requests and moved forward with this data collection effort.
While the AHA will continue to press its concerns with CMS, the survey requires that all 340B hospitals submit acquisition cost data during the survey response period beginning April 24, 2020 and ending May 15, 2020. Specifically, 340B hospitals will be asked to provide information on the average acquisition costs for SCODs bought by hospitals during the fourth quarter of 2018 and the first quarter of 2019. The survey asks for the net acquisition costs for each SCOD acquired through the 340B program. Acquisition cost is defined as the price that hospitals pay upon receiving the product (the sub-ceiling price after all applicable discounts); this includes, but is not limited to, 340B drugs purchased via a replenishment model under the 340B program or under penny pricing. The 340B drug acquisition cost should be reported regardless of whether or not the drug was dispensed or whether the drug was dispensed in multiple settings during the specified time period. Drugs acquired by 340B hospitals outside of the 340B program are not included in the survey. The survey documents, instructions regarding the survey and how to submit the completed survey can be found here.