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Association Comments on Proposed 340B Acquisition Cost Survey

In a March 9 letter to the Office of Management and Budget (OMB), America’s Essential Hospitals urged the withdrawal of a proposed Centers for Medicare & Medicaid Services (CMS) survey of hospitals in the 340B Drug Pricing Program.

The proposed survey, which CMS expects 340B hospitals to complete between March 23 and April 10, will collect acquisition cost data for 340B drugs. CMS plans on using this data to set payment rates for Medicare Part B drugs administered at 340B hospitals if a federal appeals court finds the agency’s current payment rate of 77.5 percent of average sales price (ASP) to be unlawful.

In the letter, the association expressed concern that a proposed drug acquisition cost survey would impose excessive burden on hospitals in the 340B program and would raise many operational challenges. The association asserted 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.

OMB is reviewing the proposed survey under the Paperwork Reduction Act of 1995, which requires federal agencies to submit proposed information collection requests to OMB for approval. America’s Essential Hospitals will update members once OMB completes its review and CMS issues further guidance on the survey. CMS mentions in the proposed survey that hospitals should check their individual Medicare Administrative Contractor websites for further information about the survey once it is published.

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



About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.

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