On August 27, 2015, the U.S. Department of Health and Human Services (HHS) released the long-awaited and much-anticipated proposed 340B Drug Pricing Program (340B Program) Omnibus Guidance (Proposed Guidance). The Proposed Guidance addresses most of those 340B Program eligibility and compliance requirements that are not subject to HHS formal rulemaking authority. 

The impact of the Proposed Guidance includes the following:

• Significantly revised definitions of

   

  • Drugs eligible for discounted 340B prices and

  • Patients eligible to receive such discounts

• Future alterations including compliance with the group purchasing organization (GPO) prohibition, contracts with governmental entities to support 340B Program eligibility, auditable records requirements, dispensing of 340B drugs to Medicaid managed care enrollees, and contract pharmacy oversight, among other topics 

McDermott Will & Emery invites you to attend this complimentary webcast, which will highlight key takeaways of the Proposed Guidance. Health care providers participating in the 340B Program will learn how the Proposed Guidance could impact common current 340B Program practices and should not miss this program! 

The webcast will focus on the implications to the 340B Program if the Proposed Guidance is implemented as proposed and how to respond to the Proposed Guidance.