Upcoming 340B Deadline: HRSA Mandatory Recertification Begins August 10th
The Health Resources and Services Administration (HRSA) announced that this year’s 340B recertification period will begin on August 10 and will run through September 7. The recertification process is mandatory in order to maintain eligibility in the 340B program. Hospitals’ Authorizing Officials are expected to receive notifications from HRSA on or about August 8. These notifications are essential for recertification.
340B recertification requires (1) approving your 340B Covered Entity’s details in the Office of Pharmacy Affairs’ (OPA) database and (2) acknowledging 340B regulatory compliance. The OPA will send an e-mail to the Authorized Official for each participating entity with the information necessary to complete recertification. Each 340B hospital must review all of the enrollment information included on the OPA database to ensure its accuracy.
For the 2016 340B recertification, Medicaid updates are especially important. Medicaid 340B billing compliance is continuing to become an increasingly challenging endeavor – including both fee-for-service and managed care. Hospitals that do not correctly update their enrollments and follow their state’s Medicaid billing requirements could be at risk for Medicaid duplicate discounts. Murer recommends that hospital 340B stakeholders review their enrollment record with payor contracting to ensure that all in- and out-of-state Medicaid numbers are listed. This is also an appropriate time to review Medicaid Managed Care practices to ensure compliance with your state’s requirements.
Covered Entities should also be aware that HRSA has altered two phrases in the recertification attestation that could potentially broaden reporting responsibilities. The new language states that Covered Entities are required to contact HRSA in the event of an eligibility “change” or compliance “breach” related to 340B. Previously, the attestation only required contacting HRSA in the event of a “material change” or “material breach.”
If you have any questions regarding the 340B recertification process, or if you are interested in Murer assisting further with your 340B Program, please feel free to contact us.