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Association Comments on Proposed 340B Acquisition Cost Collection

In a Nov. 27 letter to the Centers for Medicare & Medicaid Services (CMS) Office of Strategic Operations and Regulatory Affairs, America’s Essential Hospitals expressed concern that a proposed drug acquisition cost survey would impose excessive burden on hospitals in the 340B Drug Pricing Program and would raise many operational challenges.

The letter was sent in response to a notice announcing that CMS plans to develop and distribute a survey to collect acquisition cost data from hospitals participating in the 340B program.

In its comments, the association asserts that the proposed collection exceeds CMS’ authority under  Medicare statute and emphasized the administrative burden such a survey would place on essential hospitals. The association urged CMS not to implement the proposed collection without fully considering the impact it will have on 340B hospitals.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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