August 19, 2016

Demonstrating That 340(b) Loses Are Recouped By Increased Prices To The Public

The shortcomings in the 340(b) program have been studied for years.  One reason for the lack of action is that the implications of these shortcomings have not been presented in a manner that demonstrates they affect the consumer. In essence it appears that certain commercial sectors, pharmacies and hospitals, are benefiting at the cost of the pharmaceutical industry.

One purpose of this Interactive Public Docket(IPD) is to subject this public policy issue to an informed analysis with an interactive capability for all interested stakeholders to express their views and submit relevant data. To this end CRE controls all original posts on this page, the home page, but interested stakeholders may post directly on the two forums to the right of this page. Our readers can, however, post comments on CRE articles on the home page but they cannot post a new article.

Any of our readers who have relevant information should either post on the reports forum to the right or send it to                 

The deficiencies in the 340(b) program have been disclosed in a number of publications over a considerable period of time. Nonetheless the deficiencies have not been corrected and one may argue have worsened over time. One of the most significant deficiencies in the program programs is that although the discounts to serve an indigent individual must go to a “Covered Entity -CE”, like a hospital or pharmacy,  any individual visiting a CE, indigent or not, is  eligible for a discount.

The problem is that the consuming public have not become involved in the debate in large part because it appears that several commercial sectors, pharmacies and hospitals, are benefiting at the cost of the pharmaceutical industry.  In other words it appears that the 340(b) issue is simply an argument among titans of industry.

The purpose of this forum is to demonstrate that the losses sustained by the pharmaceutical industry in the 340(b) program are passed through to the average consumer through price increases for a wide range of pharmaceutical products.

We encourage any of our readers to post relevant information in the Reports Forum to the right of this post.

As our initial exploration of the aforementioned issue we have identified a study which could demonstrate that increases in Medicaid rebates results in price increases to the general public.  The study we have identified is  Danzon Pricing and Reimbursement (1).

As we review this report we welcome comments from stakeholders.

References: Pharma White Paper

Opposition to Pharma   White Paper and Blog

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