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Covered Entity Search. Start at www.hrsa.gov/opa. Click on this link. Click on this link. Select the entity type and enter data to find a specific entity. CE Decision to Not Use 340B Drugs Carve-Out. When a CE enrolls, its data are entered in the CE database. CE Data.

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Covered Entity Search

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Covered entity search

Covered Entity Search

Start at www.hrsa.gov/opa

Click on this link

Click on this link

Select the entity type and enter data to find a specific entity


Ce decision to not use 340b drugs carve out

CE Decision to Not Use 340B DrugsCarve-Out

When a CE enrolls, its data are entered in the CE database.

CE Data

If the entity is NOT using 340B-purchased drugs for their Medicaid fee-for-service patients, the form will indicate that the entity will not bill Medicaid for drugs purchased at 340B prices.


The medicaid exclusion file

The Medicaid Exclusion File

Reasons why most 340B entities exclude Medicaid prescriptions from their contract pharmacy:

  • Most contract pharmacies and Medicaid agencies do not “establish an arrangement to prevent duplicate discounting.”

  • Medicaid reimbursement formulas based on actual 340B cost may not provide margin sufficient to cover costs.

  • Most clinics and pharmacies are aware that the Medicaid anti-kickback statute is very broad and are wary of including Medicaid prescriptions in their contracts.


Ce decision to use 340b drugs carve in

CE Decision to Use 340B DrugsCarve-In

When a CE enrolls, its data are entered in the CE database.

CE Data

If the entity is using 340B-purchased drugs for their Medicaid fee-for-service patients, the form must display the Medicaid number and state.


When a ce has more than one npi

When a CE Has More Than One NPI

When a CE enrolls, its data are entered in the CE database.

CE Data

The OPA database is capable of handling entities that have more than 1 NPI and wish to bill different state Medicaid agencies in a different manner (e.g., carve-out in 1 state, and use 340B for another). On the registration form, the entity must specify that the NPI is listed in association with particular states.


Alternative agreement with state

Alternative Agreement With State

OR

  • The CE must work with its state Medicaid agency and OPA to establish sufficient safeguards.


Medication exclusion file data extract

Medication Exclusion File Data Extract

Go to: http://opanet.hrsa.gov/opa/default.aspx

Click on “Search Medicaid Provider Numbers”

http://opanet.hrsa.gov/opa/CEMedicaidExtract.aspx


Medicaid exclusion file data

Medicaid Exclusion File Data

Go to http://opanet.hrsa.gov/opa/MedicaidExclusionFiles.aspx or the OPA’s home page and click on “Medicaid Exclusion Files”


Ce responsibility for avoiding duplicate discounts

CE Responsibility for Avoiding Duplicate Discounts


Avoiding duplicate discounts

Avoiding Duplicate Discounts

What can CEs and states do to avoid Duplicate discounts on 340B drugs?

States

CEs

  • Become knowledgeable about duplicate discount prohibition by using HRSA and PVP resources

  • Have a knowledgeable 340B “go-to” person in the state Medicaid office who is available to communicate with 340B entities

  • Review the Medicaid Exclusion File

  • If discrepancies are noted, contact the CE for more information

  • Provide clear direction to CEs about your Medicaid 340B reimbursement policy and their responsibilities

  • Let OPA know if there are concerns or areas for improvement

  • Become knowledgeable about duplicate discount prohibition by using HRSA and Prime Vendor Program (PVP) resources

  • Evaluate your Medicaid billing practices: are you using 340B medications in ANY Medicaid prescriptions?

  • Review your entry in the OPA database: does it correctly match your practices?


Office of inspector general oig report june 2011

Office of Inspector General (OIG) ReportJune 2011

OIG. State Medicaid policies and oversight activities related to 340B-purchased drugs. June 2011. OEI 05-09-00321. Available at: http://oig.hhs.gov/oei/reports/oei-05-09-00321.pdf. Accessed November 22, 2011.


340b resource information

1-888-340-2787

[email protected]

340B Resource Information

Health Resources and Services Administration

http://www.hrsa.gov/opa/

http://www.hrsa.gov/publichealth/clinical/patientsafety/index.html

340B Prime Vendor Program Managed by Apexus

https://www.340bpvp.com/


Covered entity search

Thank you for viewing this 340B tutorial developed by :

Health Resources and Services Administration

Office of Pharmacy Affairs

340B Peer-to-Peer Program

You can view additional 340B educational products and tools specifically developed to assist 340B-participating entities create and maintain processes to ensure 340B program integrity at:

www.hrsa.gov/opa/peertopeer/


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