LDH Provides Clarification Around 340B Drug Pricing and Rebate Program

Date: 04/24/20

On behalf of Louisiana Department of Health (LDH), Louisiana Healthcare Connections would like to share with providers a revision to information bulletin 16-9. The latest revisions provides additional clarification around the 340B drug pricing and rebate policy.  

A brief summary of updates include:

• The overlap of the 340B Drug Pricing Program and the Medicaid Drug Rebate program creates the possibility of duplicate discounts, which are prohibited under federal law.
• States are federally mandated to seek federal drug rebates on managed care Medicaid claims, meaning that the potential for duplicate discounts exists for managed care claims.
• Louisiana uses the Health Resources and Services Administration’s (HRSA) Medicaid Exclusion File (MEF) for both Fee-for-Service (FFS) and managed care Medicaid claims in order to prevent duplicate discounts.
• Contract pharmacies are not permitted to bill Medicaid for drugs purchased at 340B pricing. This includes both FFS and managed care Medicaid.
• Effective July 15, 2019, pharmacy claims submitted by pharmacies on the MEF for hepatitis C virus direct acting antiviral (DAA) agents will deny.
• Starting June 1, 2020, all 340B claims shall deny when the appropriate 340B claim level indicators are not included.

Providers should review the complete Informational Bulletin 16-9 for additional details.