Beginning April 1, 2019, after many years of delay, HRSA will provide 340B covered entities access to a database of 340B ceiling prices for the first quarter of 2019 and each quarter thereafter, enabling covered entities to confirm whether they have been overcharged for 340B drugs.  But, what process may covered entities use to collect overcharges and will covered entities be able to recoup past manufacturer overcharges? Click here for a memorandum from the 340B attorneys within Powers’ drug pricing practice detailing the current legal and regulatory landscape surrounding 340B overcharges and what steps covered entities can take to recover those overcharges.

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