340B Unscripted

In this episode, Greg and Rob catch up on various looming deadlines for 340B providers.  That includes submitting responses to the HRSA 340B Rebate Request For Information (RFI), as well as submitting drug purchasing data for the CMS ODACS.   Additionally, they talk about struggles with the 340B/MFP reconciliation process and manufacturer policies requiring claims submission.
 
As referenced in the episode, here is the CMS ODACS acquisition data template:
https://www.cms.gov/files/zip/odacs-acquisition-data-template.zip
 

In this episode, Greg and Rob are joined again by healthcare attorney Emily Cook. They discuss a recent HRSA Information Collection Request (ICR) that describes some changes being made to the 340B enrollment, registration and recertification processes. They also discuss recent industry observations around hospital disproportionate share percentage calculations and impact on 340B Program eligibility.
Going to 340B Coalition Winter Conference in San Diego? Come see the SpendMend team at booth #418!

In this episode, Rob and Greg are joined by guest Andy Ruskin, healthcare attorney and government payer expert from K&L Gates. They’ll be discussing the 2026 CMS OPPS Final Rule, focusing on the provision related to the ODACS, or Outpatient Drug Acquisition Cost Survey. They’ll review the statutory landscape surrounding the survey, recap past attempts by CMS to lower 340B hospital reimbursement, and discuss considerations for hospitals as they contemplate how to respond this time around.
In the intro, the guys review updates to manufacturer 340B policies. Specifically, they discuss a new policy from one manufacturer that conditions 340B pricing access for in-house pharmacies on claim submission requirements. 

In this episode, Greg and Rob share some initial reactions around the recent judicial activity affecting HRSA's 340B rebate model. They'll discuss thoughts on the federal court ruling that halted the rebate model from going into effect, and also debate what the fallout could be for manufacturers and covered entities given the lack of a regulated deduplication process for MFP and 340B prices. They'll also discuss some of the preliminary steps hospitals might need to take in response to the CMS OPPS Drug Acquisition Cost Survey.
Email us at 340BUnscripted@spendmend.com if you have questions or topics for us to cover!

In this episode, Greg and Rob recap key developments in the 340B space from 2025.  They’ll discuss the flurry of activity in recent months related to 340B rebates, project the impact of the OBBB on DSH hospitals, share insights from HRSA audit trends over the last year, and offer commentary on one of the few high points for 340B providers this year – state legislative activity. Also, Rob offers a heartfelt pep talk for 340B folks at the end of the episode – so make sure you listen through to the end!
Medi-Cal Provider Guidance on 340B Rebates:  https://mcweb.apps.prd.cammis.medi-cal.ca.gov/news/33779
Email us at 340BUnscripted@spendmend.com with your questions and comments!

In this episode, Greg and Rob are joined by Katheryne Richardson of the Beacon team, to discuss frequently asked questions about the upcoming 340B rebate model.  They’ll cover the differences between Beacon applications, commonly asked questions regarding data submission, and tips for covered entities to consider as the implementation date approaches.
Come see us at Booth #1545 during this year’s ASHP Midyear Clinical Meeting!

In this episode, Greg and Rob catch up on some clarifications gained around the upcoming 340B rebate model, including purchasing requirements and developments with select chain retail pharmacies updating their policies. Additionally, they discuss the CMS CY2026 OPPS final rule that was just published, including potential implications for 340B hospitals.
CMS Hospital Drug Acquisition Cost Survey Info: https://www.cms.gov/medicare/payment/prospective-payment-systems/hospital-outpatient-pps/outpatient-prospective-payment-system-opps-drug-acquisition-cost-survey
Come see us at booth #1545 at the ASHP Clinical Midyear Meeting December 8-11 in Las Vegas!

In this episode, Greg and Rob share initial reactions to the HRSA update on 340B rebate model implementation. They’ll review the communication provided by HRSA on October 30th on their website, as well as discuss some of the manufacturer letters published on October 31st, that formally communicate rebate policies to 340B stakeholders.
 
HRSA 340B Rebate Website: https://www.hrsa.gov/opa/340b-model-pilot-program
Beacon Manufacturer Resources Website (includes letters): https://cm.beaconchannelmanagement.com/pages/resources
 
Email us at 340BUnscripted@spendmend.com with questions, comments and topic suggestions!