340B program and the sustainability of comprehensive health services to vulnerable populations

The 340B program was created by Congress in 1992 to help uninsured indigent patients gain better access to prescription medicines. This program has allowed ‘covered entities' to stretch federal resources and cover uncompensated health services given to indigent patients, but not without criticism from various stakeholders. This presentation will give a basic overview of the 340B program; explore issues and strategies for program compliance; and the future of the program in light of the Affordable Care Act (ACA). As insurance coverage expands due to ACA, the 340B provider enrollment is expected to grow at historical rates. This presentation will explore the possibility of recalibrating the 340B program so that its benefits continue to be targeted to uninsured, indigent patients whom Congress sought to help when it created the program. In light of the growing complexity of the 340B program, this presentation will postulate and discuss potential market distortions that could arise at the hospital, pharmacy, and clinical decision making levels. Both HRSA and the Office of Pharmacy Affairs (OPA) are increasing the number of annual 340B audits making it imperative for all covered entities to have a comprehensive compliance plan – and this presentation will give covered entities the motivation and key elements in developing their compliance plans.