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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.
Narration (00:02)
Welcome to 340B Insight from 340B Health.
David Glendinning (00:10)
Hello from Washington DC and welcome back to 340B Insight, the premier podcast about the 340B drug pricing program. I'm your host, David Glendinning with 340B Health. Our guest for this episode is Olivia Little with Johnson County Hospital in Tecumseh, Nebraska. Olivia is a familiar face to many of you and a familiar presence in the 340B world because of her deep commitment to 340B advocacy.
As part of such efforts, a coalition of Nebraska hospitals recently was successful in helping enact 340B contract pharmacy protections in the state. But that's not the end of the story. We wanted to speak with Olivia about what happened for hospitals starting the day that those protections officially took effect. But first, let's do a quick recap of some of the latest news about 340B.
The Health Resources and Services Administration is seeking stakeholder input on a potential revival of the type of 340B rebate model that was set to take effect January 1st before federal courts blocked it. HRSA released a Request for Information, or RFI, that includes asking covered entities to submit extensive detailed data, contract terms, and other information pertaining to potential costs under such a model.
The notice says the agency is seeking the information to determine if a rebate pilot program is, quote, in the public interest, end quote, and if so, to determine how it should implement those rebates consistent with federal law. Despite the extensive amount of data it seeks, the RFI sets a very short deadline of March 19th for submissions. Please visit the show notes to learn more about this request and how hospitals can respond.
And now for our feature interview with Olivia Little with Nebraska's Johnson County Hospital. Olivia was one of the many experts presenting at the most recent 340B Coalition Conference. She was part of a rural health roundtable discussing what happens for hospitals after the lawmakers in their state put 340B contract pharmacy protections in place. We caught up with Olivia just after her presentation to chat more. Here's that conversation.
I am speaking with Olivia Little, is the 340B director at Johnson County Hospital. Olivia, thank you for joining us here at the 2026 340B Coalition Winter Conference. Welcome to 340B Insight.
Olivia Little (02:53)
Well, David, thank you for having me today.
David Glendinning (02:56)
I am a little bit surprised we haven't had you on yet actually because you've been such a ⁓ 340B champion in so many ways for us, know, videos, op-eds, district visits, hill visits, certainly at all the conferences. so thank you for being here. If you could please tell us a little bit to start about Johnson County Hospital and the patients you serve there. That'd be great.
Olivia Little (03:18)
Johnson County Hospital is a critical access hospital located in DeKumst, Nebraska. It's about an hour and a half south of Omaha. We have 18 beds and we have one hospital and two rural health clinics with one of those clinics attached to the hospital and the other about 22 miles away in a neighboring county. Our population is 1,700 and our county population is about 5,000.
David Glendinning (03:43)
Okay, so definitely, you know, serving a pretty remote rural community, I would imagine. Yes. And what are some of the ways in which Johnson County Hospital uses its 340B savings for patient care?
Olivia Little (03:57)
So we look at this every year. We go through our community benefits, what worked the year before, where can we extend our dollars to have, you know, the biggest bang for your buck? How is it going to impact our patients and our communities the largest? One of our most recent uses of our $340B is we bought an ambulance and we started an EMS transfer service. So when you call 911, you still get the volunteer EMS squad, but
We own our own ambulance and so we can transfer. The nearest ambulance group is almost an hour away. We have to wait for bed acceptance before we can transfer a patient. Since we bought our own ambulance and we have paramedics now 24-7, we can transfer patients as soon as we get our bed acceptance. And we found out it's a huge need in the area and our paramedics also serve other local county hospitals when we're not using them.
So that was a great use of our 340B dollars to start that program. And they are, you know, a program now that they can fund themselves. So now we can take those 340B dollars that may have been earmarked for that previously and we can put it back into the community for another use.
David Glendinning (05:15)
Great example. Thank you. We're here to speak today about something Nebraska did relatively recently, one of more than 20 states so far that have passed legislation to protect access to 340B pricing through contract pharmacies. Nebraska is one of those more than 20. Could you start by briefly walking us through what that Nebraska law does when it took effect? Any other details you think are relevant?
Olivia Little (05:43)
The law allows us to have delivery of 340B drugs to all of our contract pharmacies. It's not capped on a number. And also something we put in there was that we did not have to submit claims or medical data. And it went into effect on April 9th of 2025. We wrote it with an emergency clause in it. So the date it was signed was the date it went into effect.
David Glendinning (06:09)
And I understand you were personally very involved in getting this bill over the finish line and getting it passed through the legislature and then, you know, obviously having the governor sign it. Can you talk a little bit about that experience?
Olivia Little (06:21)
We really, introduced our first run at this in January of 24. Before that though, a lot of things went into play. We had met with our state hospital association, but we'd also met with hospital associations from other states that had already passed state contract pharmacy law. And, you know, we're in the midst of some lawsuits because we wanted to get our wording correct. We also worked with 340B Health on our bill draft to see
you know, what we could do to improve upon. So that did get introduced into the legislature in January of 24. And we did not get to testify until towards the end of the session. And since we were so far at the end, we just didn't get a lot of traction. So we spoke with the senator that introduced it, and he committed to reintroducing it in the 2025 session. We started looking at where other states were successful in their lawsuits.
at the appeals court level and seeing what worked. So we also try to put a lot of foresight into the bill. They weren't really talking about medical claims data at that time, but we thought, okay, we're going to do this from the contract pharmacy side on claims data, but let's look at from the medical side too. we also put that language in. we had our bill introduced in January of 25.
Then we went and testified in February of 25 in front of the banking commerce and insurance committee and it passed out of committee and onto the floor. And we actually made an amendment to the bill. A distribution group wanted us to remove one word. And so we went back and forth over it, didn't think it was going to do much to hurt our bill. So we removed the one word and we ended up getting it passed and it was signed on April 9th of 2025 by our governor.
The signing ceremony was quite the experience. I got asked to attend it and possibly, you know, just say a few words. I thought I was going to show up into his office, just a few of us in there. No, it was in a fairly large room. There was media. It was live on TV. It was a little more than what I expected. I didn't expect to take a media questions on TV for it.
David Glendinning (08:38)
Well, that is great that you were so involved you got to be there. Sorry, it was a little nerve wracking being in the spotlight there as it were, but certainly for a good cause. It certainly sounds like it was quite the hospital and other provider coalition that went into getting this over the finish line. normally that might be the end of the story as advocacy communications people ⁓ like me would maybe consider that to be the end of that story. But we're kind of here to talk about what happens after.
bill becomes law and needs to be needs to be implemented. So once this law passed in Nebraska, what was generally the first thing you were watching for as a 340 B director at a hospital?
Olivia Little (09:23)
And so we didn't quite know what to expect. That once the law went into effect, would we get notifications from manufacturers? Would our pricing be stored immediately? And we saw a very wide range ⁓ of things like that that happened. By the time I got back to my computer, about an hour after the signing ceremony, I had already had notifications of pricing restored from some manufacturers. And we already had a lawsuit filed against the state of Nebraska, you know, all within an hour drive home from our capital.
I came up with a process of a very colorful spreadsheet listing all the manufacturers and going through a checklist. Have I got a notification? Has the pricing been restored in our wholesaler? Has the pricing been restored in our TPA? Do our contract pharmacies know? Because if you do a physical inventory with your contract pharmacies, well a virtual inventory, but they actually get physical drug shipments, they need to be aware of this
because drugs that had not previously qualified are now qualifying and they're starting to ship in. So they're going to have a big inventory swell. On the notifications on Varying Widely, somewhere an email from 340B ESP with an attached document with the manufacturer letterhead telling us, you can now get drug pricing, 340B pricing back to an eliminated out of contract pharmacies.
Some of them said our policy you're exempt from since you're seeing the state of Nebraska. Some of them didn't address the claims and medical data submissions. So I did make it a point on the manufacturers that did not address that. I would reach back out to them and just say, hey, our state law says we don't have to submit data to get access to the delivery of 340 B drugs. And so we wanted to get clarification of that.
and to have it in writing. Now, in all of this, my big take-home point of any of this is make sure you keep the documentation. So, since we had a wide array of notifications, emails from ESP, some with a nice attached document, some saying, hey, the policy has been updated, go to our resource center and see the new policy, some were an email from ESP.
that had two to three sentences that didn't even look official. I actually would reach back out to him and say, you know, is this for real? Is this sure? And so we saved all of that communication. I getting ready for this podcast, I went back through some of those emails and I tried a link to the document because some of the manufacturers, even though they gave us an exemption, have still to this day not updated their online policy. And the letter they sent to me, you know, via email,
is I've never seen it publicly posted anywhere and the link to that no longer exists. So just keep the documentation. Otherwise you're going to have to go back through and reach out to manufacturers. Then we would hit the situations of what do we do when we didn't get a notification? One, we would reach out the 340B ESP. And we found in the end that was kind of the way to go. They were kind of in between, but we could get to the right person. When we try to...
go directly to the manufacturer, you were really trying to find an email to get to the right person, you know, to get to somebody that had the authority to say yes or no, and to get that back in writing. Some of the manufacturers we never got notifications on, we found the pricing was already restored in our wholesalers. So then we kind of juggled between, the pricing's loaded, but yet their public policy still says we can't access this. So
Since it's loaded though, do we go ahead and access it or do we respect their policy and not? So we did make it a point. We went out to those manufacturers and, you know, asked for clarification and writing. We just wanted to be on the safe side. And again, make sure you have the documentation.
David Glendinning (13:30)
Wow, interesting. So even after all this time, there's still some of those drug companies who you still haven't officially heard anything from ⁓ in the aftermath of this. What kind of issues could that cause for hospital like yours?
Olivia Little (13:43)
So since we still aren't able to get the 340B delivery of the drugs, therefore no 340B pricing, so we're still not qualifying those at some of our contract pharmacies. So that's still, there's money on the table, there's revenue out there, that if we would be able to get or get our savings on, we would be able to provide more community benefits and different areas of care for our patients. And so we still are actively trying to
reach out to manufacturers, even though they've told me no once or twice or told me this matter is now considered closed. You know, I'm going to give it a little bit more time and go back to them and just ask again, you know, have they reconsidered their policy? And some of them, we just can't even quite understand why they're not giving us the pricing back when some of our neighboring states pass their laws months after us and they have.
their pricing back, but yet we don't. And I haven't been able to get a clear answer on a lot of that from the manufacturers.
David Glendinning (14:47)
Okay, still certainly a lot to track of, you know, progress or lack of progress in some of these cases. You had mentioned earlier having a system for tracking all of this pretty closely. How do you continue to stay organized just seeing, you know, where each drug company is in this journey?
Olivia Little (15:05)
Again, I have a very colorful spreadsheet, you know, green for all go and red for no, that was a definite no on our request. I keep a lot of notes in there about different dates of conversations and documents I've saved, you know, how we communicated via email, real mail, or directly or 340 BSP. But we came up with a process in the first place when we got a notification, we saw pricing was maybe not there right away.
So we started reaching out to our wholesalers, to the manufacturer and say, hey, you sent us this notification, where's our pricing at? By the time somebody actually got back to me or a possible real answer, the pricing was already loaded. So we figured out pretty quickly on that once we got that notification, if we just held for about three days, that pricing would be loaded into our wholesaler.
It'd be active in 340B ESP. We'd have it in our TPA. And it was all done for us without having to reach out and spending time on phone calls and emails. And so again, this is all written down in an Excel spreadsheet. And that way we can reference back. So if I have a contract pharmacy call me and say, hey, why did drug XYZ, why didn't this qualify for 340B?
Well then I can look up the drug by the manufacturer and I can go back in to see if this was a manufacturer that gave us the pricing back or not. You think you'd have this memorized at this point on who you have it back from or not, but there's just so many manufacturers out there, it gets complicated.
David Glendinning (16:46)
So I think I'm starting to hear of some of these best practices along the way, but hopefully that number of states that have these contract pharmacy protections will continue to grow and there will be other folks out there, your peers in different states who are going through the same journey as you are in the aftermath of that. What can you impart to them in terms of some of the biggest lessons you've learned during this process?
Olivia Little (17:11)
Well, if we could go back and redo this, we would have had a better game plan in place for once the law was signed into effect. You we thought we were prepared, but then questions came up that we just didn't have the answer for. And, you know, we were making decisions on the fly. A quick phone call and we're like, okay, we have to make a decision now. Some of those being knowing what you're going to do once you get a notification.
So we got notifications right away. We got them in July and August, September, you know, months and months afterwards. And some of them would say, hey, this policy goes in effect as of April 9th of 25, even though we didn't get it until September. So then we look at it. OK, do we want to backdate all of the claims from this manufacturer and re-qualify them?
and retest them for 340B status. So we talked with our contract pharmacies because they get physical shipments in and we asked them what they'd want to do. And they said, no, please don't. We don't want the inventory swell. So we had to think about it in our organization. You know, there's lost revenue out there that you'd leave on the table. But you know, what was best for everyone? Can we really monitor and track this going all the way back? Or do we try to get credit rebills?
and just trying to see what to do. And the other thing was dates. It would say maybe back to April 9th, but others were only back a few days. So we kind of just went on the fly. What is good in our organization? What was good for our contract pharmacies and what we could really handle as a facility and, you know, compliance and documentation and making sure this was all correctly happening. And so that was something.
we would have liked to, looking back now, know more about it.
David Glendinning (19:08)
And since you were so closely involved with actually getting this legislation through the legislature and enacted, what advice might you have for states that aren't quite at this point yet that are still, you know, maybe trying to push to get these protections in place before they can even start thinking about the day after plan?
Olivia Little (19:28)
I would say don't lose hope. For us, this wasn't something that happened overnight. It took us several years and it took a couple attempts in the legislature to get it passed and you have to just keep coming back. But that gave us a chance to figure out our wording in the bill. Where do you put the comma? Let's make this very plain language so we're not trying to fight. What was the intent of it? Or somebody 10, 20 years later.
trying to see what we were trying to do at the time. So it gave us some time to really what we think we should say perfect it. We know it's not perfect, but we did our best. So yes, don't lose hope. Just keep trying. Keep going, keep advocating with your state legislature. Get out on social media. Right before this was passed, when it's still being considered, I worked with the public media broadcasting company.
you know, to do an article and some recording snippets on it. You know, we were just trying to get the word out to anybody that would listen and try to educate them that 340B is good for our patients, know, our hospitals and our communities.
David Glendinning (20:39)
Well, thank you for your persistence and for your dedication to that cause ⁓ and for helping getting this enacted. And ⁓ hopefully some other hospitals can be inspired by that and start to, you know, maybe be able to think about some of those day after issues that we've been chatting about today. So thank you again for your time and and your passion.
Olivia Little (21:00)
Well, David, I appreciate you having me and have a great rest of the conference.
David Glendinning (21:05)
You too.
Our thanks again to Olivia Little for keeping up her strong advocacy work on behalf of her hospital and others in her state. This includes doing everything possible to make sure that when state contract pharmacy protections become law, they also become a practical reality for the hospitals those laws are meant to protect. This is the first of several episodes we recorded at the 340B Coalition Winter Conference in San Diego that we will be releasing in the coming months. Thank you to everybody who stopped by the podcast booth to say hello.
We will be back in a few weeks with our next episode. the meantime, as always, thanks for listening and be well.
Narration (21:46)
Thanks for listening to 340B Insight. Subscribe and rate us on Apple Podcasts, Google Play, Spotify, or wherever you listen to podcasts. For more information, visit our website at 340bpodcast.org. You can also follow us on Twitter @340BHealth and submit a question or idea to the show by emailing us at podcast@340bhealth.org.