On April 1, the AAMC submitted comments on the Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of 340B (SUSTAIN 340B) Act and related request for information. This discussion draft legislation was released earlier this year by the Senate “Gang of Six,” a bipartisan group of six senators who have traditionally led on the 340B program — Sens. John Thune (R-S.D.), Debbie Stabenow (D-Mich.), Shelley Moore Capito (R-W.Va.), Tammy Baldwin (D-Wis.), Jerry Moran (R-Kan.), and Ben Cardin (D-Md.).
In its comments, the AAMC expressed appreciation for certain provisions of the discussion draft, including a proposal that would codify covered entities’ ability to employ contract pharmacy arrangements to distribute covered outpatient drugs. The letter also highlighted serious concerns regarding many policies in the discussion draft, including restrictions on hospitals’ use of child sites, additional transparency and reporting measures, and a proposal to define “patient” in 340B statute. The comments emphasized that many of these proposals are misaligned with Congress’ intent for the 340B program and would impose additional administrative burden and expenses on safety-net providers that participate in the program.