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Potential ACA Reform Sets the Tone at National 340B Conference

The 13th Annual 340B Coalition Winter Conference was held in San Francisco, CA the first week of February.  “The City,” known for its landmarks, spirited culture, and some of the best restaurants in the world, welcomed over 1,400 health care and business professionals from across the nation for this latest 340B conference.

The Hudson Headwaters 340B Pharmacy Services Team was in attendance at the 340B conference, to learn more about audit findings, on-going compliance challenges and solutions, and new federal and state Medicaid policies, while also interacting with current and prospective clients at our booth.

Compliance was again the main concern of session speakers at the 340B conference and for those who visited our booth, however, the uncertainty surrounding the new administration, Congress, and the future of the 340B program was rampant.  Just days prior to the start of the conference, the Health Resources and Services Administration (HRSA) pulled the pending 340B Program Omnibus Guidance and subsequently chose not to participate during their scheduled 340B Update from HRSA session on Thursday, February 2nd.

President Trump and GOP-controlled Congress have been very vocal about their desire to repeal the Affordable Care Act (ACA).  A full repeal of the ACA would have a profound impact on certain hospital types whose 340B eligibility was established through the ACA.  Other program oversight measures included in the ACA, some which are already being implemented, could also be repealed, having a negative impact on program integrity.  This, combined with the new executive order requiring withdrawal of two regulations for each new regulation, makes it difficult to predict whether HRSA would consider reissuing guidance in the near future.

For now and the foreseeable future, 340B program control and oversight will remain the same.  It will be important for covered entities to adhere to the current regulatory requirements, monitor HRSA, Office of Pharmacy Affairs, and Apexus announcements, and continue to exhibit adequate program oversight.  HRSA announced a partnership with the Bizzell Group in November, who is to complete 200-300 340B program audits in 2017.

As some elected representatives have vocalized their belief that the 340B program has grown beyond its original intent, we will continue to closely monitor 340B program developments.  This opinion on 340B may conflict with that of the new administration, who has praised mechanisms that would result in lower drug prices. As a 340B Covered Entity and Third Party Administrator, our goal is to collaboratively protect the integrity of the program through preparation for potential program reform and, as always, we aim to be a continued resource to our clients and other 340B stakeholders.

Concerned about the future of 340B? Interested in protecting program integrity? Reach out to learn more about our services and how Hudson Headwaters 340B Pharmacy Services can help you meet your goals. Give us a call (855-835-340B) or send an email ( We’re in this together, so let’s do it right.