On July 26, the AAMC responded to a request for information (RFI) on the 340B Drug Pricing Program issued by a bipartisan group of six senators. The RFI, which aims to improve “integrity and stability” in the program, contains six questions examining various aspects of the program, including: the Health Resources and Services Administration’s oversight, covered entities’ use of contract pharmacy arrangements, and measures to promote transparency and accountability.
In its response, the AAMC highlighted how the 340B program enables its members to care for low-income and historically underserved patients. In addition, the letter described how AAMC-member institutions leverage partnerships with community-based pharmacies (also known as contract pharmacies) to expand access to care for patients, particularly those living in rural areas or facing transportation barriers. The association outlined how pharmaceutical manufacturers’ restrictions on contract pharmacies impact both covered entities and the patients they serve, noting that these “unfair and unlawful restrictions on contract pharmacy arrangements place an undue burden on patients, imposing yet another obstacle in their path to care.”
The AAMC provided several recommendations to strengthen the 340B program and ensure that it continues to benefit covered entities and the patients they serve. To address the mounting impacts of contract pharmacy restrictions, the association recommended clarifying and codifying protections for these arrangements in federal 340B statute. In addition, the AAMC emphasized its support for the Preserving Rules Ordered for the Entities Covered Through 340B Act of 2023 (H.R. 2534), which would prohibit payers from imposing discriminatory reimbursement policies on 340B-covered entities. The letter concluded with actionable recommendations to promote transparency and accountability in the program, such as through tangible improvements to the administrative dispute resolution process and audit parity between manufacturers and covered entities.