COVID-19 has impacted nearly every area of hospital operations, including the 340B program. Because of the pandemic, HRSA has revised location eligibility guidance. HRSA states that covered entities may be able to consider patients 340B-eligible in new locations outside the four walls of the hospital building even if the new location has not yet appeared as reimbursable in a filed Medicare cost report (MCR) and is not yet registered with the 340B Office of Pharmacy Affairs Information System (OPAIS).

Location Eligibility HRSA Updated Guidance

Prior to COVID-19, HRSA required a location to be included on a reimbursable line of the MCR (between lines 50 and 118) in order to be eligible and registered. Due to COVID-19, HRSA now allows locations that are otherwise eligible but do not yet appear on the MCR to use 340B drugs. 

Under this revised policy, a covered entity’s eligible outpatient locations can now access 340B drugs for patients who meet current 340B eligible patient standards prior to the location appearing as reimbursable in the MCR, as long as the outpatient facility meets MCR rules. HRSA’s expectation is that the location will be registered with OPAIS as soon as it appears on a filed MCR as reimbursable. Clinical Services Crosswalk is key to tracking eligible locations.

CPS 340B Location Eligibility Support

With more than 20 years’ experience managing over 500 hospital 340B programs, CPS knows the drug discount program better than anyone. For more information about how CPS 340B teams can help your organization with 340B location eligibility, contact the CPS 340B team: contactus@cpspharm.com.