January 18, 2013—Federally qualified health centers (FQHCs) will have three weeks beginning Feb. 5 to recertify their eligibility for 340B drug discounts, the National Association of Community Health Centers (NACHC) is reminding its members.
NACH posted the alert on its blog on Jan. 18.[ms-protect-content id=”2799″] The Health Resources and Services Administration (HRSA) Office of Pharmacy Affairs (OPA), which administers the 340B program, held a webinar for health centers about the recertification requirement on Jan. 10.
The Affordable Care Act required OPA to recertify the eligibility of all 340B covered entities annually. FQHCs are among the last entity types to go through the process. Hemophilia treatment centers (HTC) are also being recertified for the first time in February and OPA held a webinar for them on Jan. 7.
According to the NACHC blog post, OPA will send emails on Feb. 1 to each health center’s 340B authorizing official and the person the center listed as its primary contact in OPA’s 340B database. The authorizing official’s email will contain the password he or she needs to access OPA’s recertification website. NACHC urged its members to confirm the accuracy of their authorizing official’s and primary contact’s name and email address in OPA’s database “as soon as possible” and to make sure that their authorizing official knows the email is coming.
Health centers “must register each delivery site in their approved scope of project at which patients are prescribed and/or receive 340B drugs,” NACHC wrote. The group also reminded its members to “pay particular attention to indicating whether or not they dispense 340B drugs to Medicaid fee-for-service beneficiaries” in order to avoid incurring liability for Medicaid “claiming a rebate to which it is not entitled.”
NACHC also pointed out that the recertification process requires authorizing officials “to personally certify to the FQHC’s compliance with numerous 340B program requirements.”
“The [authorizing official] and key personnel involved in administering the FQHC’s 340B program should review these certifications carefully before submitting,” it said.
NACHC said that, according to OPA, “FQHCs that do not recertify within the three week window will be deemed ineligible and dropped from the FQHC database.”
“OPA is not likely to give individual extensions,” it said. “Therefore, a timely response to the recertification is very important since the FQHC may have to wait until the next general registration period that begins April 1, 2013, to re-register.”[/ms-protect-content]