By: Marcus J. Hopkins, Policy Consultant
Before we get started on explaining how the 340B Drug Pricing Program (340B) can be leveraged to increase treatment options for people living with Hepatitis C (HCV), it really is vital to understand what 340B is, its intended purpose, and how it’s utilized:
The 340B Drug Pricing Program was created in 1992 and requires pharmaceutical manufacturers to provide front-end discounts on covered outpatient drugs purchased by specified government-supported facilities – “covered entities” – that serve the nation’s most vulnerable populations (i.e. – the poor, rural populations, people living with HIV and other illnesses, Native Hawaiians, Tribal/Urban Indian Health Centers, et cetera). The savings from the purchase of these steeply discounted drugs are supposed to be used to pay for care at no cost to taxpayers.
There are numerous conversations to be had about 340B and the various issues and abuses the program sees by various entities, and the Community Access National Network released, last year, a comprehensive report on the topic of 340B and reports that CANN feels are necessary in order for the program to fulfill its ideals. That report can be found here. This blog entry is focusing, instead, on how existing covered entities can leverage 340B and its savings to better treat patients living with HCV.
When focusing on the Liver Disease aspect of HCV, 340B hospitals are able to provide liver assessments and education (from savings), chronic liver and biliary disease management (from savings), liver medication management (from savings), and disease treatment (from medication purchases). When it comes to the types of providers most likely to be able to successfully leverage 340B purchasing and savings to address HCV, there are four common types of providers of HCV treatment and services that can potentially be 340B recipients: hospitals, community health centers, Ryan White clinics, and STD clinics.
As statistics from the Centers for Disease Control and Prevention (CDC) have shown for the last four years, rates of HCV are increasingly higher in largely rural states that have a high incidence of Substance Use Disorder/Opioid Use Disorder and Injection Drug Use (IDU). In many of these states, such as Kentucky, Ohio, Tennessee, and West Virginia, access to healthcare services is often limited to a handful of options, many of which are sole community hospitals (SCHs) – hospitals that “…by reason of factors such as isolated location, weather conditions, travel conditions, or absence of other hospitals, is the sole source of inpatient hospital services reasonably available in a geographic area to Medicare beneficiaries.”
These SCHs are likely some of the only available options for people living with HCV to receive treatment. Because they are hospitals, there are fewer restrictions on how 340B savings can be utilized, which unfortunately has led many of these entities to use the program as a source of “income,” rather than utilizing the savings to reinvest in patient care. It behooves them to use those savings to create HCV-specific programs to better engaging patients in care, help them to manage medication and medication adherence, and to increase regimen completion rates and Sustained Virologic Response rates.
If I’m being 100% honest – which I usually am (often to my detriment) – unless you are directly involved in the money side of treatment issues, the 340B program and its intricacies are both confusing and overwhelming. For 340B providers, they are often met with complex billing and reimbursement requirements for 340B drugs; for patients, the whole conversation about 340B is just…too much information, when all they should really be worried about is addressing their HCV. These various workaround and payment mechanisms and schemes are so far above most patients’ paygrades that getting patients to advocate for a program that is increasingly difficult to navigate for providers is a battle that I think we (as healthcare advocates) are likely to lose.
That said, there are options for providers who are covered entities to utilize 340B drug pricing to increase access to medication and savings from those purchases to create and maintain medication adherence programs and patient engagement efforts. It just comes down to keeping those rural hospitals open long enough to ensure they can even do so.
- Community Access National Network. (2019, February). 340B Commission’s FINAL REPORT ON THE 340B DRUG DISCOUNT PROGRAM – The Issues Spurring Discussion, Stakeholder Stances and Possible Resolutions. Washington, DC: Community Access National Network. Retrieved from: https://docs.google.com/gview?url=http://www.tiicann.org/pdf-docs/2019_CANN_340B_Commission_Final-Report-v5_03-07-19.pdf&embedded=true
Disclaimer: HEAL Blogs do not necessarily reflect the views of the Community Access National Network (CANN), but rather they provide a neutral platform whereby the author serves to promote open, honest discussion about Hepatitis-related issues and updates. Please note that the content of some of the HEAL Blogs might be graphic due to the nature of the issues being addressed in it.