October 6, 2015
Proposed 340B Omnibus Guidance

Tuesday, October 6, 2015 | 12:00 PM (Central)

This webinar provides an in-depth analysis of the Health Resources and Services Administration's (HRSA) proposed 340B Omnibus Guidance ("Mega-Guidance"). HRSA released the long-awaited proposed Mega-Guidance on August 28, 2015 as discussed here. The webinar included an overview of practical implications of the Mega-Guidance, if finalized, and recommended next steps regarding the submission of comments (due October 27, 2015). The presenters focused on some of the key proposed changes that may have a significant impact on various 340B stakeholders and provided the opportunity for participants to ask questions.

On our agenda:
  • Significant overhaul of the patient definition, including new restrictions that may reduce the scope of the 340B Program;
  • Changes to Medicaid managed care organization billing in the contract pharmacy setting;
  • Changes to the scope of the definition of a covered outpatient drug;
  • Program integrity and annual audits.

  • Travis F. Jackson, Principal, Polsinelli
  • Kyle A. Vasquez, Counsel, Polsinelli