MHA Draft Comments Available for Medicaid FFS 340B Drug Reporting

Posted on April 27, 2018

The Medical Services Administration (MSA) recently released a proposed policy establishing a final settlement adjustment process to standardize the reporting of hospital outpatient drug costs for Medicaid fee-for-service (FFS) settlement purposes. Existing MSA policy requires hospitals that participate in the Medicaid FFS 340B drug discount program to report acquisition cost for these drugs, while non-340B hospitals report charges. The proposed policy would allow 340B hospitals to provide the MSA with charges for use in determining their final settlement amounts.

Although the proposed policy would not impact Medicaid reimbursement for 340B drugs, providing the MSA with charges, in addition to the required cost data, would increase Medicaid outpatient upper payment limits and potentially result in fewer hospitals being subject to Medicaid FFS payment recoveries. The proposed policy would be effective for final settlements for fiscal years ending on and after Oct. 1, 2015, and would not apply to prior settlements or settlements reopened prior to the effective date.

In its draft comments, the MHA:

  • Requested clarification that hospitals would not be required to adhere to the proposed changes, but that Medicaid FFS 340B hospitals could voluntarily participate in the 340B final settlement adjustment process by providing the MSA with claims-level documentation reflecting both acquisition cost and charges.
  • Requested clarification that the proposed changes do not impact hospitals that do not participate in the Medicaid FFS 340B drug discount program.
  • Recommended that the MSA develop a reporting tool to capture future charge and acquisition cost data to help streamline reporting and make it consistent among hospitals.

The MHA encourages hospitals to submit comments to the MSA by May 4. Members with questions should contact Vickie Kunz at the MHA

Tags: Medicaid, 340B Drug Pricing Program, prescription drugs, comments, proposed policy

Posted in: Member News

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