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On behalf of
As an association with 340B member hospitals, we have seen first-hand how hospitals are using the program savings to improve patient services and help their communities, as
From an implementation perspective, this survey will significantly burden all 340B hospitals. These facilities operate on thin margins and already incur considerable costs to ensure they are compliant with program rules and requirements. These costs include dedicated staff time, as well as complex health information and inventory management systems. The survey would require considerable resources to gather the data requested, convert the data into the requested format, and complete everything within the time specified. In addition, to complete the survey, hospitals would need to access and assess proprietary drug prices from wholesalers. These hospitals purchase many of their 340B drugs through wholesaler purchasing arrangements. These arrangements are contractual agreements that often include strict non-disclosure conditions that restrict the sharing of any drug pricing information to any entity not party to the contract. These non-disclosure provisions would make it exceedingly difficult for 340B hospitals to share the data necessary to complete the survey in the time specified.
Thank you for your consideration of our comments. We strongly urge CMS to withdraw this survey and cease any further Medicare Part B payment policies that will undermine the intent of the 340B program.
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The notice can be viewed at: https://www.regulations.gov/document?D=CMS-2019-0142-0001