On Jan. 8, 2020, the Centers for Medicare and Medicaid Services (CMS) released a new Information Bulletin, Best Practices for Avoiding 340B Duplicate Discounts in Medicaid. While the bulletin makes clear that the exclusion file is solely for fee-for-service Medicaid (not managed care), an issue on which the Department of Human Services had disagreed with PACHC, there are also provisions of the bulletin that might prove problematic. PACHC and NACHC are reviewing the bulletin and its implications.
