Newly-Announced 340B Payment Rule Presents Financial & Operational Challenges to All Covered Entities

In its 2018 Outpatient Prospective Payment System final rule (Final Rule) issued Nov. 1, Centers for Medicare and Medicaid Services (CMS) implemented a significant Medicare Part B payment reduction for separately payable, non-pass-through drugs provided in the hospital outpatient setting. CMS also finalized several new modifiers that will present significant operational challenges, given a very short turnaround time to implement.

It is critical that all covered entities take action now to combat implementation of the 340B provisions in the Final Rule and to develop an action plan to implement the use of CMS’s new modifiers.

Find the Final Rule here. Read Polsinelli’s analysis of CMS’s initial proposal here.

To view the full e-alert, including an analysis of key concepts, click here.