Drug Discount Monitor

340B Hospital Recertification Set for 3rd Week of April & 1st Week of May

Revised dates and other new details emerge in second OPA webinar.

March 30, 2012—The Office of Pharmacy Affairs (OPA) now plans to begin recertifying the 340B eligibility of children's and free-standing cancer hospitals, rural referral centers (RRCs), and sole community hospitals (SCHs) during the third week of April, followed by disproportionate share (DSH) and critical access hospitals (CAHs) during the first week of May, the OPA official managing the recertification effort said during a March 28 webinar, its second on the topic.

OPA's Pharmacy Services Support Center (PSSC) had previously reported that on either April 9 or April 23, hospital senior executives responsible for their institution's enrollment in 340B would receive an email containing the username, password, and instructions they will need to personally recertify that their hospital and all of its registered outpatient sites are eligible for the drug discount program.

During the OPA webinar, Lt. Cmdr. Joshua Hardin also clarified that a hospital's authorizing official and the individual listed as the hospital's primary contact in OPA's covered entity database would both be notified in advance by email of the date that the authorizing official will be sent the email with the recertification username, password, and instructions.

The authorizing official will have three weeks from receipt of that second email to complete the reauthorization procedure, he said.

Hardin also reiterated that it is "essential" for hospitals to ensure that their authorizing official's email address and other contact information is up to date in OPA's database. He said hospitals also should ensure prior to recertification that all of their other information in the database is accurate and, if necessary, make revisions using the change request form. OPA has received more than 800 change requests thus far and it is taking about two weeks for changes to be made, he said.  If a hospital submitted a request prior to March 1 as OPA had recommended and its information still has not been updated in the database and OPA has not contacted it for additional information, Hardin said it should resubmit the request.

Hardin also said that, while it is not a requirement, a hospital "should" register all of its 340B-eligible outpatient facilities that appear on its most recently filed Medicare cost report so as to have "a clear and conscious mind" that all such facilities are eligible for the 340B program.

He also said that authorizing officials "should expect in advance" to be able to provide the date of their hospital's last filed cost report and its DSH patient percentage from that report while they are completing the recertification process, he said.

In addition, Hardin said that:

• The recertification requirement applies only to outpatient facilities that have been enrolled in 340B for one or more years. If an outpatient facility or "child" site has been enrolled for less than a year, it is possible that an authorizing official might not see it listed when he or she logs in to begin the recertification process.
• Outpatient clinics are eligible for 340B only after they have appeared on their hospital's most recently filed cost report.
• Hospitals do not need to file a change request form if all of their information in the OPA database "is correct and true and accurate."
• Filing a change request form is not the same as recertifying eligibility. Just because a hospital has filed a form, Hardin said, does not mean that it has been recertified.
• Hospitals must supply OPA with their Medicaid provider number and/or National Provider Identifier if they use 340B-purchased drugs to fill Medicaid prescriptions.
• Hospital-owned pharmacies cannot be registered as child sites of a parent 340B hospital. If a pharmacy is part of a clinic, the clinic should be registered. If a pharmacy serves multiple parts of a hospital, it should be listed as a "ship to" address for the hospital.

Physician clinics may be registered as child sites only if they are listed as reimbursable on an as-filed cost report.