June 26, 2014—Hospitals will have from Aug. 6 through Sept. 10 to recertify their eligibility for the 340B drug discount program, the Health Resources and Services Administration announced during a webinar today.[ms-protect-content id=”2799″]
HRSA said the hospital executive who legally authorizes his or her institution to participate in the drug discount program—typically, the CEO or another C suite official—will receive an email from HRSA around Aug. 1 with the user name and password he or she needs to complete the recertification process on the Office of Pharmacy Affairs 340B database website. Other recertification emails from HRSA will go both to this authorizing official and to the person listed in the 340B database as the hospital’s primary contact—often, its pharmacy director.
This is the third year that hospitals are going through the mandatory recertification process. As it has in years past, HRSA urged the capacity crowd of 500 hospital representatives on the webinar to make sure their email and other contact information in the 340B database is up to date and that their hospital’s email spam filters are set to allow communications from HRSA. The agency also advised hospitals to proactively verify all of their other information in the database and submit necessary change requests well in advance of the recertification start date.
Many blanks in hospitals’ electronic recertification forms will be pre-filled this year with information pulled from Centers for Medicare and Medicaid Services databases. This is expected to include hospital ownership status, Medicare disproportionate share adjustment percentage, and offsite outpatient locations listed with CMS. Also new this year, the recertification form now includes a field, also expected to be pre-filled, for the hospital’s Internal Revenue System employer identification number.
Before he or she can submit the recertification form, a hospital’s authorizing official must attest that the institution abides by program requirements as outlined in eight statements on the form. The webinar slides indicate that one of these statements (number three) has changed from the version hospitals were required to attest to in 2013.
First, in 2013, a hospital had to attest it “will comply with” all program requirements. The webinar slide indicates the wording has been changed to “is complying with.”
Second, the new attestation appears to exclude language from the 2013 version that the hospital complies with requirements and restrictions pertaining to “the exclusion of orphan drugs for critical access hospitals, free-standing cancer hospitals, sole community hospitals and rural referral centers.”
Safety Net Hospitals for Pharmaceutical Access, which represents hospitals enrolled in 340B, has posted a copy of the webinar slides here.[/ms-protect-content]