July 2, 2013—All 340B hospitals will need to recertify their eligibility for the drug discount program during a four-week period that will begin in mid-August, but the exact start date has yet to be announced, a Health Resources and Services Administration (HRSA) representative said during a webinar last week.[ms-protect-content id=”2799″]
Unlike last year, when hospitals enrolled in the program for less than a year were excused from recertifying, this year all hospitals listed in the 340B covered entity database will need to go through the process. The only exception, HRSA said, is hospitals “with a pending termination date.”
HRSA delayed hospital recertification until after Aug. 7, the deadline it gave disproportionate share (DSH), children’s, and free-standing cancer hospitals to come into compliance with its revised prohibition on buying covered outpatient drugs through a group purchasing organization (GPO). A hospital’s inability to meet the GPO exclusion requirements “would require termination prior to recertification,” according to one of the slides shown during the webinar. The same slide stated that if an entity determines that a site needs to be terminated, it needs to be prepared to provide:
- the date that the reason for termination was effective;
- a brief description of the facts surrounding the reason for termination and how the effective date was determined; and
- the last day that 340B drugs were or will be purchased under the site’s 340B identification number.
HRSA also has revised the list of program compliance attestations that hospital authorizing officials must sign during recertification to include a statement that, if applicable, the hospital complies with the prohibition on participating in a GPO.
In another change from last year’s recertification, this year all categories of 340B hospitals will be recertifying their eligibility during the same four-week time period. In 2012, HRSA divided hospitals into three groups—(1) free-standing cancer hospitals, children’s hospitals, rural referral centers, and sole community hospitals; (2) DSH hospitals; and (3) critical access hospitals—and had the groups go through the process on different dates.
During the webinar, HRSA once again emphasized that that it is important for hospitals to verify the accuracy of their information in the 340B covered entity database between now and mid-August, especially the email addresses and other contact information for their authorizing official and primary contact.
HRSA also reminded hospitals that must meet a Medicare DSH adjustment percentage threshold to participate in 340B that they “will need to have their last filed CMS Cost Report Worksheet E, Part A” and will be required to enter the reporting period and DSH percentage.
Click here for a copy of the entire slide presentation.[/ms-protect-content]