Express Scripts, a large US-based PBM, announced a new 340B retrospective claims identification requirement. The new policy may impose significant burdens on 340B pharmacies and threaten the viability of safety net providers.
On February 24, Express Scripts, one of the largest pharmacy benefit managers (PBMs) in the United States, issued a notice stating that, beginning March 1, pharmacies must retrospectively identify drugs dispensed by 340B safety-net providers and their pharmacies. Express Scripts’ new policy requires 340B pharmacies to provide data to Express Scripts through the untested “N1 transaction” process established by the National Council for Prescription Drug Programs (NCPDP) more than ten years ago. Simply put, Express Scripts requires 340B safety-net providers and pharmacies to submit additional data on each prescription dispensed with 340B drugs to their patients, a data entry process that may require an unfeasible amount of time and resources. For those pharmacies that refuse to comply, Express Scripts may audit them, issue costly recoupment fees, and/or terminate the pharmacies from the Express Scripts network.
340B safety-net providers and their pharmacies are primarily concerned that the new requirements, and the short deadline to comply with them, will impose significant burden on our Nation’s safety-net providers and may result in loss or a decrease in 340B benefits. Several pharmacies that contract with 340B safety-net providers have expressed an inability to expend significant amounts of their pharmacy staffs’ time to comport with the policy. They note that the policy could hinder their pharmacy staff from providing important pharmacy services, including drug utilization review and patient counseling. Therefore, safety-net providers risk losing the participation of their 340B contract pharmacies, and 340B patients risk losing the convenience and access to low-cost 340B drugs at those pharmacies. Ultimately, 340B safety-net providers may lose significant 340B savings and revenue, which they use to provide free and low-cost healthcare services to underserved communities.