August 3, 2012—The Office of Pharmacy Affairs (OPA) is no longer relying on disproportionate share (DSH) adjustment percentage data from the Centers for Medicare and Medicaid Services (CMS) to assist in the determination of whether a hospital qualifies for 340B, and it will not be posting DSH payment percentages on its Web site any longer.
The following announcement recently appeared on the OPA site: “Disproportionate Share Adjustment Percentage data is no longer available through the Office of Pharmacy Affairs.[ms-protect-content id=”2799″] The previous list was provided by the Centers for Medicare and Medicaid Services to assist HRSA in validating compliance with 340B program requirements; we are assessing alternate data sources at this time.”
OPA has not stated what alternate data sources it is considering. However, some observers think that OPA may rely on the DSH payment percentage information that each hospital provides in the annual recertification process. In addition, OPA expects hospitals to self-report on an ongoing basis if their DSH adjustment percentage on their most recently filed cost report is below the 340B threshold.
Due to delays in data reporting, the DSH payment percentages on the OPA Web site sometimes have not matched the DSH percentages on hospitals’ most recently filed cost reports for several months. The OPA site would indicate with an asterisk all hospitals that had a DSH payment percentage above 11.75 percent, which is the 340B qualifying percentage for most urban hospitals. If a hospital disagreed, it could submit DSH data from its most recently filed cost report to OPA.[/ms-protect-content]