(May 8, 2020) – A concerted effort led by the American Hospital Association continues to urge the Centers for Medicare & Medicaid Services to withdraw the 340B hospital survey launched last month to collect actual acquisition costs for specified covered outpatient drugs. The survey requires that all 340B hospitals (except 340B Critical Access 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. 340B hospitals required to complete the survey are given an option to do a "Quick Survey," which allows CMS to utilize the Health Resources and Services Administration 340B ceiling prices for the hospitals' 340B purchased drugs. Otherwise, 340B hospitals can complete the long form of the survey, which defines acquisition cost 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.