More Contract Pharmacy Oversight for HHS 340B Program, in Law360March 5, 2014
Constance Wilkinson, a Member of the Firm in the Litigation and Health Care and Life Sciences practices, in the Washington, DC, office, and Alan Arville, a Member of the Firm in the Health Care and Life Sciences practice, in the Washington, DC, office, co-wrote an article titled "More Contract Pharmacy Oversight for HHS 340B Program." (Read the full version — subscription required.)
Following is an excerpt:
By way of background, the U.S. Department of Health and Human Services' 340B Drug Discount Program, codified as Section 340B of the Public Health Service Act ("340B program"), requires drug manufacturers to give discounts to entities covered under the law, known as covered entities, in order to have their drugs covered by Medicaid. The manufacturer must agree to sell each of its outpatient prescription drugs to covered entities enrolled in the 340B program "at or below a ceiling price" that is derived from the same average manufacturer price and unit rebate amount calculated under the Medicaid Drug Rebate Program.