Principals William von Oehsen and Barbara Williams and Associate Shuchi Parikh presented at the 14th Annual 340B Coalition Conference in San Diego last month.

The three-day event consisted of educational sessions focused on all aspects of the federal 340B drug discount program. Topics at the 340B Coalition Conference included legislative activity affecting the 340B community, developments regarding Medicaid billing and reimbursement, contract pharmacy management and compliance, how to ensure 340B program compliance and more.

Powers Presentations at 340B Coalition Conference

Bill von Oehsen presented at and served as the moderator for the Thursday session titled “How to Survive a HRSA Audit and Take Corrective Action,” which focused on how covered entities should prepare for a HRSA audit and take corrective action when a compliance issue is detected.

Bill has been involved with the 340B Program for more than 25 years. He played a key role in helping to enact the program in 1992 and to expand the law in 2010 under the Affordable Care Act. In 1997, he helped organize the 340B Coalition, which now represents a dozen national organizations whose members comprise virtually all of the safety net providers participating in the 340B program.

Barbara Williams participated in the Friday panel discussing “Medicare Payment Cuts to 340B Hospitals: Operationalizing Modifiers and Evaluating Next Steps”. The session focused on new Medicare rules that reduce Medicare Part B drug payments to certain 340B hospitals, along with advocacy efforts to reverse the cuts.

Barbara’s presentation focused on new Medicare billing modifier requirements and compliance issues associated with these requirements.  Under the new rules, 340B hospitals must use a modifier to identify 340B drugs that are subject to the Medicare Part B payment cuts and, in some instances, another modifier to identify claims that are not affected by the payment cuts.  The rules went into effect for services provided on or after Jan. 1, 2018, after CMS finalized the new policies last November.

Barbara advises clients on compliance with the requirements of the 340B drug discount program and on preparing for, and responding to, 340B audits.  Barbara also focuses on Medicare and Medicaid reimbursement issues, both in advising clients on meeting regulatory requirements and with representing clients before the Provider Reimbursement Review Board.

Shuchi Parikh presented during the “340B Lessons from the Field” session on Thursday, which was designed to provide covered entities with information on vendors’ experiences and “lessons learned” from advising clients on challenging 340B issues. Her presentation covered recent developments in Medicaid billing and reimbursement requirements for 340B drugs.

Shuchi has experience counseling 340B covered entities, including hospitals, federally qualified health centers, Ryan White Clinics, and others, on a variety of 340B-related matters. Shuchi also advises 340B covered entities on contracting matters involving the 340B program.

Powers Trivia Event

Powers hosted a 340B trivia event,  in conjunction with the 340B Coalition Conference, where the firm introduced Counsel Brad Lang. Brad worked for more than twelve years at the Health Resources and Services Administration’s Office of Pharmacy Affairs administering the 340B Drug Pricing Program. At OPA, Brad provided broad policy support on 340B implementation issues and both developed and wrote published guidance and proposed regulations governing use of the program.

Powers Principal Peggy Tighe moderated the event, providing insight into the current status of the 340B program and how the 340B community can fight to preserve the program. Ten teams competed in the trivia contest, and three teams were deemed winners. For photos of the event and a sample of trivia questions, visit the Powers Facebook page.

For more information regarding the 340B program, contact Bill von Oehsen at William.vonOehsen@PowersLaw.com, Barbara Williams at Barbara.Williams@Powerslaw.com or Shuchi Parikh at Shuchi.Parikh@PowersLaw.com.

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