OMB Approves 340B Survey Amid COVID-19 with Required Response by May 15

Thoughtware Alert Published: Apr 27, 2020
Healthcare CMS

With most of the healthcare world focused on the SARS-CoV-2 virus and the incidence of COVID-19 health emergency, facilities may not have the 340B Hospital Drug survey top of mind. However, on April 23, 2020, the Office of Management and Budget approved the CMS survey to collect cost information for specified outpatient-covered drugs from hospitals participating in the 340B Drug Pricing Program. The survey response period is April 24, 2020, through May 15, 2020. Hospitals enrolled in the last quarter of 2018 and/or the first quarter of 2019 (with the exception of critical access hospitals) are expected to respond. Hospitals have the option of completing the “Detailed Survey” or the “Quick Survey.” If completing the Quick Survey, the hospital would indicate it prefers that CMS use the 340B Drug Pricing Program (340B Program) ceiling prices obtained from the Health Resources and Services Administration as reflective of its acquisition cost. Hospitals should consider whether this is accurate and assess the risks and benefits of both options.

As noted in a previous BKD Thoughtware® article, on February 7, 2020, CMS published a notice in the Federal Register seeking public comment on the finalized survey until March 9, 2020.

CMS has previously indicated its intent to use the collected drug cost information to re-examine reimbursement and set payment rates based on cost. Hospitals have expressed concern regarding the timing of this survey, as they’re currently focused on responding to COVID-19. Hospitals are expected to take approximately 48 hours to collect all data needed to complete the Detailed Survey option. 

The updated 340B Program survey instructions and submission template can be found on CMS’ website.

As with most topics related to COVID-19, changes are being made rapidly. Please note that this information is current as of the date of publication. BKD can assist your organization with completing the survey. If you need assistance or more information on these matters, please reach out to your BKD Trusted Advisor or submit the Contact Us form below.

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