340B Insight

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Earlier this year, the Health Resources & Services Administration took a strong stance against drug giant Johnson & Johnson’s plan for a proposed 340B rebate model, but the fight over rebates is far from over. 340B Health President and CEO Maureen Testoni joins us to discuss how the company is taking the issue to federal court and how they are not the only drugmaker doing so.

J&J Sues HRSA Over Rebates

J&J is arguing in court that HRSA lacks the authority to block a 340B rebate model. Such a model would allow individual drug companies effectively to impose their own rules on 340B drug purchases. These rules would curtail the number of drugs a company would offer a 340B discount on and reduce the number of patients that would be deemed 340B-eligible.

Other Drugmakers Pushing Rebates

Bristol Myers Squibb and Eli Lilly also sued HRSA, claiming the agency does not have the authority to stop a rebate model. Sanofi has not yet filed suit but is saying it will impose its rebate scheme in early January. The Sanofi model raises significant concerns not just because of the imminent effective date but because it would impose far more stringent restrictions on 340B eligibility than HRSA ever has.

State Contract Pharmacy Laws Rack Up More Wins

In another 340B issue before the federal courts, state contract pharmacy protections continue obtaining key litigation wins. Several district courts and one appeals court have upheld state laws designed to protect covered entity access to 340B pricing through community and specialty contract pharmacies.

Resources:

  1. Brief Your Leadership on Drugmaker Rebate Schemes
  2. The Wall Street Journal: “The Economic Imperative of Protecting 340B”
  3. Register for the 340B Coalition Winter Conference

Creators and Guests

DG
Host
David Glendinning
IW
Editor
Ismael Balderas Wong
TH
Producer
Trevor Hook

What is 340B Insight?

340B Insight provides members and supporters of 340B Health with timely updates and discussions about the 340B drug pricing program. The podcast helps listeners stay current with and learn more about 340B to help them serve their patients and communities and remain compliant. We publish new episodes twice a month, with news reports and in-depth interviews with leading health care practitioners, policy and legal experts, public policymakers, and our expert staff.

Intro [00:00:04]:
Welcome to 340B Insight from 340B Health.

David Glendinning [00:00:11]:
Hello from Washington, D.C. and welcome back to 340B

David Glendinning [00:00:15]:
Insight, the podcast about the 340B drug pricing program.

David Glendinning [00:00:19]:
I'm your host David Glendinning with 340B Health.

David Glendinning [00:00:23]:
Our guest today is 340B Health President and CEO

David Glendinning [00:00:26]:
Maureen Testoni. We speak with Maureen regularly

David Glendinning [00:00:30]:
and wanted to have her back on the show to give us a year end

David Glendinning [00:00:34]:
wrap up of all the developments in the 340B world.

David Glendinning [00:00:38]:
So here's that conversation. Today we

David Glendinning [00:00:41]:
are speaking again with 340B Health President and CEO

David Glendinning [00:00:45]:
Maureen Testoni. Maureen, thank you for making the time to

David Glendinning [00:00:49]:
be with us. And welcome back to 340B Insight.

Maureen Testoni [00:00:52]:
Thank you, David. I really appreciate the opportunity.

David Glendinning [00:00:54]:
It is December now, believe it or not, and you were

David Glendinning [00:00:58]:
last on the show in late September. What has been

David Glendinning [00:01:02]:
happening in 340B since then?

Maureen Testoni [00:01:04]:
I think the biggest issue in 340B has been a number

Maureen Testoni [00:01:07]:
of drug maker proposals to turn

Maureen Testoni [00:01:10]:
340B into a rebate. Other issues

Maureen Testoni [00:01:14]:
are that we're really focusing on are litigation

Maureen Testoni [00:01:17]:
around state contract pharmacy laws. There

Maureen Testoni [00:01:20]:
was also the first release of its

Maureen Testoni [00:01:24]:
kind by a state that had

Maureen Testoni [00:01:27]:
imposed certain reporting requirements on 340B hospitals.

Maureen Testoni [00:01:31]:
And that is something else that's new and I think

Maureen Testoni [00:01:35]:
important to understand.

David Glendinning [00:01:38]:
Let's start with the rebates. As I know that's been such a big deal

David Glendinning [00:01:41]:
for the 340B community and you just called it the number one concern at this

David Glendinning [00:01:45]:
point. Listeners of the show will know that Johnson and

David Glendinning [00:01:49]:
Johnson paused implementation of its rebate model

David Glendinning [00:01:52]:
after HRSA threatened strong enforcement actions. What

David Glendinning [00:01:56]:
is the latest on that issue?

Maureen Testoni [00:01:58]:
Johnson and Johnson has now sued hrsa. They're essentially saying that

Maureen Testoni [00:02:01]:
HRSA does not have the authority to block a rebate model.

Maureen Testoni [00:02:05]:
And since then, we're also seeing three other

Maureen Testoni [00:02:08]:
manufacturers come out saying that they

Maureen Testoni [00:02:12]:
want to do a rebate proposal. Bristol Myers,

Maureen Testoni [00:02:16]:
Squibb and Lilly have also sued

Maureen Testoni [00:02:19]:
HRSA, saying that they don't have authority to stop

Maureen Testoni [00:02:23]:
a rebate model. And both manufacturers want to impose a rebate

Maureen Testoni [00:02:27]:
model. And then Sanofi announced that it

Maureen Testoni [00:02:30]:
was going to go forward and impose a rebate model effective

Maureen Testoni [00:02:35]:
January 6th. So we'll see if

Maureen Testoni [00:02:38]:
that goes forward there. But that is something that is obviously very concerning

Maureen Testoni [00:02:42]:
because of the short date.

David Glendinning [00:02:46]:
And let's talk about some of the concerns that the

David Glendinning [00:02:50]:
340B community has. What are some of those main concerns about

David Glendinning [00:02:53]:
340B rebates when it comes to hospitals?

Maureen Testoni [00:02:57]:
Well, sticking with Sanofi, you know, they were,

Maureen Testoni [00:03:01]:
Sanofi was very explicit about

Maureen Testoni [00:03:04]:
the rules that they're gonna oppose before they would

Maureen Testoni [00:03:07]:
approve a 340B rebate for a drug. And it's

Maureen Testoni [00:03:11]:
very concerning because what Sanofi is saying is that we're gonna

Maureen Testoni [00:03:15]:
impose our own as to which

Maureen Testoni [00:03:18]:
individuals 340B hospitals can deem to

Maureen Testoni [00:03:22]:
be to qualify for 340B. And the rules that they're

Maureen Testoni [00:03:25]:
imposing are clearly intended to reduce

Maureen Testoni [00:03:29]:
the number of patients that hospitals can consider to be patients

Maureen Testoni [00:03:33]:
for 340B purposes. So this would essentially reduce the

Maureen Testoni [00:03:37]:
number of drugs that the company would have to offer a 340b

Maureen Testoni [00:03:41]:
discount on. Some of the things that they are

Maureen Testoni [00:03:44]:
doing is they are requiring

Maureen Testoni [00:03:47]:
that patients have been seen at the covered entity

Maureen Testoni [00:03:51]:
within two years. That is a rule that does not

Maureen Testoni [00:03:55]:
exist anywhere under HRSA's compliance

Maureen Testoni [00:03:58]:
policies. They are requiring that the

Maureen Testoni [00:04:02]:
prescription be directly linked to the type

Maureen Testoni [00:04:06]:
of medical care, to an actual service that the individual has

Maureen Testoni [00:04:10]:
received at the covered entity. And yet we

Maureen Testoni [00:04:14]:
all know that under 340 rules

Maureen Testoni [00:04:18]:
there can be follow up care, there can be referrals, referrals.

Maureen Testoni [00:04:21]:
HRSA does not make that tight a limit as to when

Maureen Testoni [00:04:24]:
340B can be used. They have

Maureen Testoni [00:04:28]:
rules around hospitals only using

Maureen Testoni [00:04:32]:
prescribers that are employed by the hospital or

Maureen Testoni [00:04:37]:
have some other type of affiliation which is really not spelled out what

Maureen Testoni [00:04:40]:
that affiliation would need to look like. They're requiring various

Maureen Testoni [00:04:44]:
types of patient encounter data to be able to make some of

Maureen Testoni [00:04:48]:
these determinations. And that is just

Maureen Testoni [00:04:51]:
very concerning that they would try to impose

Maureen Testoni [00:04:55]:
their own rules like this under a rebate program.

Maureen Testoni [00:04:59]:
And I think that's a big concern that hospitals have.

David Glendinning [00:05:02]:
And I will mention that there's no public response to the

David Glendinning [00:05:06]:
Sanofi plan from HRSA yet and no lawsuit from the company though, that

David Glendinning [00:05:09]:
says of when we are speaking today. We know things can change quickly in

David Glendinning [00:05:13]:
this area. So that covers Sanofi. What do we know at this point

David Glendinning [00:05:17]:
about the other rebate models that drug makers

David Glendinning [00:05:21]:
are pushing?

Maureen Testoni [00:05:22]:
We don't have a lot of details really on the other rebate models.

Maureen Testoni [00:05:25]:
We know that Johnson and Johnson plan to use the same

Maureen Testoni [00:05:29]:
vendor, Beacon, for processing its

Maureen Testoni [00:05:32]:
rebates. So they do have information on the types of claims,

Maureen Testoni [00:05:36]:
some of the claims data that they're looking for, but they don't really

Maureen Testoni [00:05:40]:
provide all the details as to how they're going

Maureen Testoni [00:05:44]:
to use that information to determine whether to approve

Maureen Testoni [00:05:47]:
a claim. They just say we're going to get this data

Maureen Testoni [00:05:51]:
and we will then determine whether to approve. But they're

Maureen Testoni [00:05:55]:
not really saying what you would have to show for sure

Maureen Testoni [00:06:00]:
to make sure that your claim would be approved. That's a distinction

Maureen Testoni [00:06:03]:
with Sanofi going into a lot more detail about the new rules

Maureen Testoni [00:06:07]:
that they are imposing. Similarly with

Maureen Testoni [00:06:11]:
Lilly and with Bristol Myers Scopes. We don't

Maureen Testoni [00:06:14]:
know exactly what the rules are that they are proposing.

Maureen Testoni [00:06:18]:
And that is obviously concerning for hospitals because now

Maureen Testoni [00:06:22]:
if rebates were to go forward, it's all in the hands of the

Maureen Testoni [00:06:25]:
manufacturers as to whether and when you would receive the

Maureen Testoni [00:06:29]:
340B discount that you know you are supposed to be getting that they are obligated

Maureen Testoni [00:06:33]:
to provide you under the 340B statute.

David Glendinning [00:06:35]:
Why are drug companies saying they need to impose

David Glendinning [00:06:39]:
rebates on 340B hospitals? What reasons are they giving in all of

David Glendinning [00:06:43]:
these notices and lawsuits they've been filing?

Maureen Testoni [00:06:45]:
Manufacturers have been claiming that 340B has grown, you

Maureen Testoni [00:06:49]:
know, beyond what it is supposed to grow. So they are concerned

Maureen Testoni [00:06:53]:
about the fact that a high number of their drugs are being subject to

Maureen Testoni [00:06:57]:
340B discounts than there were in 1992 when

Maureen Testoni [00:07:00]:
340B was enacted. But the truth is

Maureen Testoni [00:07:04]:
healthcare has moved from the inpatient setting in the hospital to the

Maureen Testoni [00:07:07]:
outpatient setting. So many more drugs are available in the

Maureen Testoni [00:07:11]:
outpatient setting than there were in 1992. And, you

Maureen Testoni [00:07:15]:
know, we have, you know, people aren't necessarily even getting certain heart

Maureen Testoni [00:07:18]:
surgeries anymore because they can rely on certain specialty drugs

Maureen Testoni [00:07:22]:
to address that. So it's not a surprise they are also claiming

Maureen Testoni [00:07:26]:
that three 340B covered entities are not always following the rules

Maureen Testoni [00:07:30]:
around 340B and that they believe, you know,

Maureen Testoni [00:07:33]:
HRSA isn't doing a good job with that.

Maureen Testoni [00:07:37]:
And that's, you know, you can see this with, especially with the types of rules

Maureen Testoni [00:07:40]:
that Sanofi is trying to put into place around, you know,

Maureen Testoni [00:07:44]:
does the individual patient really qualify for

Maureen Testoni [00:07:48]:
340B? But the truth is, you, the

Maureen Testoni [00:07:51]:
Sanofi does not going to be able to figure that out. You know, this is

Maureen Testoni [00:07:55]:
something you have to look at medical charts. When HRSA goes in and audits

Maureen Testoni [00:07:59]:
covered entities, they are looking at the

Maureen Testoni [00:08:02]:
charts, at the patient charts to make that determination as

Maureen Testoni [00:08:06]:
to whether the hospitals are appropriately using

Maureen Testoni [00:08:09]:
340B for the right kinds of patients. And in recent

Maureen Testoni [00:08:13]:
years, we're seeing findings in that area against

Maureen Testoni [00:08:17]:
hospitals to be very, very low. So there is just no

Maureen Testoni [00:08:20]:
evidence of widespread abuse by

Maureen Testoni [00:08:24]:
hospitals in the area of whether or not patients really

Maureen Testoni [00:08:28]:
qualify for 340 B. And another issue that they bring up

Maureen Testoni [00:08:31]:
is something that's called a duplicate discount. It's a little

Maureen Testoni [00:08:35]:
confusing. It means that if an entity

Maureen Testoni [00:08:39]:
buys a drug at the 340b price, then the Medicaid

Maureen Testoni [00:08:42]:
agency should not be requesting a

Maureen Testoni [00:08:46]:
rebate from the manufacturer for that drug. And when

Maureen Testoni [00:08:50]:
you look at the findings from HRSA audits, there is

Maureen Testoni [00:08:54]:
nothing in any of those findings to suggest that there's widespread

Maureen Testoni [00:08:58]:
duplicate discounts going on. Because the fact is, HRSA

Maureen Testoni [00:09:02]:
does not check to see whether or not a

Maureen Testoni [00:09:06]:
state actually sought a rebate and whether or not

Maureen Testoni [00:09:09]:
the manufacturer actually paid it for a 340B drug. The

Maureen Testoni [00:09:13]:
only thing that HRSA does when they go into their

Maureen Testoni [00:09:17]:
audit is identify whether the hospital

Maureen Testoni [00:09:21]:
complied with duplicate discount requirements. And those

Maureen Testoni [00:09:24]:
requirements are that the hospital has to put his billing number up on

Maureen Testoni [00:09:28]:
HRSA's website. And that way states can use that billing number to

Maureen Testoni [00:09:32]:
make, to exclude any of the drug claims that

Maureen Testoni [00:09:36]:
are for Medicaid patients. So hospitals,

Maureen Testoni [00:09:40]:
you know, if they transpose, you know, a couple of numbers in

Maureen Testoni [00:09:44]:
their, when they put it up on the website, they'll get a finding that says

Maureen Testoni [00:09:46]:
duplicate discounts. And in fact, many hospitals are able

Maureen Testoni [00:09:50]:
to get the duplicate discount finding change to, you

Maureen Testoni [00:09:54]:
know, a web site error finding because they're able to get their

Maureen Testoni [00:09:57]:
Medicaid agency to say, no, we don't even use HRSA's website. We have our

Maureen Testoni [00:10:01]:
own process for identifying 340B claims,

Maureen Testoni [00:10:05]:
and we can confirm we have not made any requests to the manufacturers for

Maureen Testoni [00:10:08]:
rebates on this entity's claims. So when we're seeing

Maureen Testoni [00:10:12]:
findings made by the government on duplicate discounts, it's really important to understand

Maureen Testoni [00:10:16]:
that does not in any way, shape or form mean that a duplicate discount actually

Maureen Testoni [00:10:20]:
occurred. And we have not seen real data

Maureen Testoni [00:10:23]:
produced by these manufacturers to demonstrate that,

Maureen Testoni [00:10:27]:
that this is actually a serious issue.

David Glendinning [00:10:30]:
Our listeners will be eager to know where this whole

David Glendinning [00:10:34]:
rebate debate leads for them. So what is

David Glendinning [00:10:37]:
340B Health doing to advocate against these rebates?

Maureen Testoni [00:10:41]:
One, now that it's in the federal courts, we will again be

Maureen Testoni [00:10:45]:
very involved with the litigation. In previous litigation

Maureen Testoni [00:10:49]:
that has been filed by manufacturers against the government,

Maureen Testoni [00:10:52]:
we have always submitted amicus briefs,

Maureen Testoni [00:10:56]:
sometimes on our own, sometimes we work with other associations. So we

Maureen Testoni [00:11:00]:
are currently in discussions with our legal counsel to determine the best

Maureen Testoni [00:11:04]:
way to interact in these cases, whether

Maureen Testoni [00:11:07]:
it is by actually intervening, which would, if we got permission to

Maureen Testoni [00:11:11]:
intervene, that would allow us to make arguments directly

Maureen Testoni [00:11:15]:
to the judge. So it gives us a little bit more of a presence

Maureen Testoni [00:11:19]:
than an amicus. However, I will mention this is

Maureen Testoni [00:11:22]:
likely to take a While this is unlikely to be a fast moving

Maureen Testoni [00:11:26]:
lawsuit, so there is, you know, there still is some time

Maureen Testoni [00:11:30]:
before the court is really going to require any briefing on this

Maureen Testoni [00:11:34]:
case. You know, I will also mention that the ira,

Maureen Testoni [00:11:38]:
the legislation about that includes provisions to allow

Maureen Testoni [00:11:41]:
Medicare to negotiate lower prices for drug is going

Maureen Testoni [00:11:45]:
to be implemented in, you know, in the coming year.

Maureen Testoni [00:11:49]:
And manufacturers are going to be submitting within a few months their

Maureen Testoni [00:11:52]:
plans for implementing how they're

Maureen Testoni [00:11:56]:
going to make the Medicare prices available. And

Maureen Testoni [00:12:00]:
it's been controversial as to how 340

Maureen Testoni [00:12:04]:
is going to fit into that. Covered entities

Maureen Testoni [00:12:08]:
are entitled to the 340b price regardless of what the

Maureen Testoni [00:12:11]:
Medicare price is. But the process that the government

Maureen Testoni [00:12:15]:
is using to implement it does conflict with

Maureen Testoni [00:12:18]:
340B in some ways. It is absolutely

Maureen Testoni [00:12:22]:
doable to do what the government is proposing. But the

Maureen Testoni [00:12:25]:
manufacturers believe that it is having a

Maureen Testoni [00:12:29]:
rebate program would make it easier for them to

Maureen Testoni [00:12:32]:
comply with the, with the government's, you

Maureen Testoni [00:12:36]:
know, process. So I think it's important that we

Maureen Testoni [00:12:39]:
have a lot of advocacy going on about the fact this is not

Maureen Testoni [00:12:43]:
needed. Rebates are not needed for the IRA as

Maureen Testoni [00:12:47]:
well. I wrote about this in a, in a Wall Street Journal essay

Maureen Testoni [00:12:51]:
recently. The IRA was never intended to transform 340B

Maureen Testoni [00:12:55]:
into a rebate system. The government has refused to require

Maureen Testoni [00:12:58]:
340B rebates either for the Medicare

Maureen Testoni [00:13:02]:
program, the drugs that are subject to the negotiation, or otherwise

Maureen Testoni [00:13:06]:
for 340B drugs. And drug makers absolutely

Maureen Testoni [00:13:10]:
have other avenues to comply with the IRA

Maureen Testoni [00:13:13]:
and 340B which the Centers for

Maureen Testoni [00:13:17]:
Medicare and Medicaid Services is saying that they are

Maureen Testoni [00:13:20]:
exploring as well. So it's important that

Maureen Testoni [00:13:24]:
we are, you know, advocating against rebates for 340B

Maureen Testoni [00:13:28]:
but also in the context of the Medicare

Maureen Testoni [00:13:31]:
negotiation scheme.

David Glendinning [00:13:33]:
At the top of the show you mentioned the contract

David Glendinning [00:13:36]:
pharmacy litigation over state laws. What is the

David Glendinning [00:13:40]:
latest status on those?

Maureen Testoni [00:13:42]:
So far we have seen a number of lawsuits from

Maureen Testoni [00:13:45]:
manufacturers and from their association

Maureen Testoni [00:13:48]:
pharmacy. And a lot of those are we're arguing

Maureen Testoni [00:13:52]:
that, you know, the states just do not have the authority to make

Maureen Testoni [00:13:56]:
any rules around 340 because 340B is a federal law. And so

Maureen Testoni [00:13:59]:
far they have lost those. So that has been

Maureen Testoni [00:14:03]:
great. However, there are some manufacturers are making

Maureen Testoni [00:14:06]:
new arguments around very technical

Maureen Testoni [00:14:10]:
issues about whether the providers retain

Maureen Testoni [00:14:13]:
title when the drugs are transferred to the contract pharmacy and some

Maureen Testoni [00:14:17]:
other issues. We are very involved in these cases.

Maureen Testoni [00:14:21]:
Cases. We do amicus briefs for all of these lawsuits along

Maureen Testoni [00:14:24]:
with a couple of others of the hospital associations and

Maureen Testoni [00:14:28]:
State associations. But we are also working

Maureen Testoni [00:14:31]:
closely with some of the attorneys that are working on some of

Maureen Testoni [00:14:35]:
these cases to assist with

Maureen Testoni [00:14:39]:
the more technical analysis about this. Whether there is

Maureen Testoni [00:14:43]:
any merit to some of these arguments

Maureen Testoni [00:14:47]:
that the manufacturers are making, I do not believe there is. But

Maureen Testoni [00:14:50]:
that is the case that we are really building up right now and that I

Maureen Testoni [00:14:54]:
expect to be the big issue in the coming year.

David Glendinning [00:14:57]:
You also said there's a new 340B report out,

David Glendinning [00:15:00]:
and our regular listeners will know that is coming from

David Glendinning [00:15:04]:
Minnesota, the land of 10,000 lakes. What does

David Glendinning [00:15:07]:
that report say?

Maureen Testoni [00:15:10]:
So this Minnesota report,

Maureen Testoni [00:15:15]:
it comes out of legislation that was

Maureen Testoni [00:15:19]:
passed in 2023 that

Maureen Testoni [00:15:22]:
requires covered any

Maureen Testoni [00:15:25]:
to submit certain information

Maureen Testoni [00:15:29]:
to the state. And one of the things that they

Maureen Testoni [00:15:33]:
required is that covered entities report the

Maureen Testoni [00:15:37]:
prices, you know, they're spending on 340B drugs

Maureen Testoni [00:15:40]:
and then how much they received from insurers, you know,

Maureen Testoni [00:15:44]:
in payment for those drugs. And that number, the number that they

Maureen Testoni [00:15:48]:
released was 630 million.

Maureen Testoni [00:15:52]:
Now, that is a calculation that we are

Maureen Testoni [00:15:55]:
really take issue with because it really overstates

Maureen Testoni [00:15:59]:
the value of 340B. 630 million is not the value

Maureen Testoni [00:16:03]:
of 340B. For the hospitals in Minnesota,

Maureen Testoni [00:16:07]:
the value is going to be lower than that. And that's because all that

Maureen Testoni [00:16:11]:
340B does is it gives a discount on the

Maureen Testoni [00:16:14]:
drug. But hospitals that aren't in 340B don't

Maureen Testoni [00:16:18]:
buy the drug at the sticker price. It's called wholesale acquisition cost,

Maureen Testoni [00:16:22]:
which is like the car sticker price. Nobody buys it at that. And so if

Maureen Testoni [00:16:25]:
they weren't in 340B, they would still be getting discounts on drugs by

Maureen Testoni [00:16:29]:
purchasing through their group purchasing organization. So the

Maureen Testoni [00:16:33]:
630 millions is a number that may apply.

Maureen Testoni [00:16:37]:
If everybody was purchasing their drugs at WAC and the

Maureen Testoni [00:16:41]:
only people that got a discount was 340B.

Maureen Testoni [00:16:44]:
So what you really want to do, if you were trying to see what the

Maureen Testoni [00:16:47]:
benefit of 340B is, is you would compare the GPO

Maureen Testoni [00:16:51]:
prices that hospitals have against what they're paying for 340B. So if

Maureen Testoni [00:16:55]:
the 340B price is 80, the GPO price is

Maureen Testoni [00:16:58]:
100, and the sticker price, the WACC price is

Maureen Testoni [00:17:01]:
200, then the real difference isn't going to be between

Maureen Testoni [00:17:05]:
that $80 and the 200. It's going to be between the $80

Maureen Testoni [00:17:09]:
for 340B and the 100 for the GPO. But even looking at

Maureen Testoni [00:17:13]:
that 630 number, it's important to understand

Maureen Testoni [00:17:17]:
what that number means in terms of how much is spent on

Maureen Testoni [00:17:21]:
patient care by Minnesota hospitals overall? And that

Maureen Testoni [00:17:24]:
is $15 billion on patient care

Maureen Testoni [00:17:28]:
last year. And about $770 million

Maureen Testoni [00:17:32]:
was spent on uncompensated, unreimbursed care. So

Maureen Testoni [00:17:36]:
that is care where the hospital received no

Maureen Testoni [00:17:40]:
compensation. You know, people that just did not have insurance or

Maureen Testoni [00:17:44]:
care where they received, you know, less than their

Maureen Testoni [00:17:47]:
costs, such as, you know, Medicaid, which

Maureen Testoni [00:17:50]:
notoriously pays much less than the cost. And then if you

Maureen Testoni [00:17:54]:
were to add to that number the underpayment that hospitals

Maureen Testoni [00:17:58]:
receive from Medicare, I personally believe that number would

Maureen Testoni [00:18:01]:
be closer to a billion dollars. And so without

Maureen Testoni [00:18:05]:
340B, it'd be very difficult for hospitals maintain that

Maureen Testoni [00:18:08]:
level of.

David Glendinning [00:18:09]:
Care if it's the end of the year. We here at 340B Health

David Glendinning [00:18:13]:
are preparing for the upcoming 340B Coalition Winter Conference.

David Glendinning [00:18:17]:
What are you most looking forward to for that meeting?

Maureen Testoni [00:18:19]:
I really love our conferences. It's just such a Great so

Maureen Testoni [00:18:23]:
many 340B minds in one place is just is

Maureen Testoni [00:18:27]:
really fun for me. And you know, this year our conference will be in San

Maureen Testoni [00:18:30]:
Diego. It'll be in February 24th to the 26th.

Maureen Testoni [00:18:34]:
I really encourage everybody who is really interested in

Maureen Testoni [00:18:37]:
340B to attend. We do a lot of

Maureen Testoni [00:18:41]:
sessions on compliance issues, including the

Maureen Testoni [00:18:45]:
inflation Reduction act, the Medicare negotiation policy that I

Maureen Testoni [00:18:49]:
talked about earlier Sessions on optimizing 340B on how

Maureen Testoni [00:18:52]:
to stay compliant. On 340B, we will have sessions to

Maureen Testoni [00:18:56]:
sort of what to expect in Washington with the new administration

Maureen Testoni [00:19:00]:
and the new Congress. And our featured speaker will be a

Maureen Testoni [00:19:03]:
Harvard professor that's going to be discussing the future of

Maureen Testoni [00:19:07]:
healthcare economics. So it's a great way to network with other

Maureen Testoni [00:19:10]:
340B people. It's a great way to learn about,

Maureen Testoni [00:19:14]:
learn new strategies that your peers may be using around

Maureen Testoni [00:19:18]:
340B. You know, sharing best practices, learning new ideas,

Maureen Testoni [00:19:22]:
talking about 340B advocacy. Early Bird registration

Maureen Testoni [00:19:25]:
is going on right now and it's going to end December 20th.

Maureen Testoni [00:19:29]:
So I really encourage people to sign up before then so you can

Maureen Testoni [00:19:33]:
secure your discounted rate.

David Glendinning [00:19:34]:
And we will be sure to put that link and a few other links of

David Glendinning [00:19:37]:
interest in the show notes so our listeners don't need to venture far to find

David Glendinning [00:19:41]:
them. Maureen, thank you for taking the time during the

David Glendinning [00:19:44]:
pre holiday rush to be with us today. We all appreciate it.

Maureen Testoni [00:19:48]:
Well, thank you so much for having me. I really appreciate it. Dave.

David Glendinning [00:19:50]:
We thank Maureen Testoni again for being with us today and

David Glendinning [00:19:54]:
all year long. And we thank you, our loyal listeners

David Glendinning [00:19:58]:
for joining us during this season of 340B Insight. This

David Glendinning [00:20:02]:
is our last episode of 2024 and we will be taking a

David Glendinning [00:20:05]:
short break while we prepare for another full season of episodes

David Glendinning [00:20:09]:
in 2025. Please keep those ideas coming

David Glendinning [00:20:13]:
for episodes and guests. You can always email us at

David Glendinning [00:20:17]:
podcast340bhealth.org have

David Glendinning [00:20:20]:
a joyous, peaceful holiday season and a happy, healthy

David Glendinning [00:20:24]:
new Year. We will be back in January. In the meantime, as

David Glendinning [00:20:27]:
always, thanks for listening and be well.

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