The Pennsylvania Medicaid Program Proposes 340B Modifier Requirement for All Managed Care Drugs

In a briefing document formatted as a Medical Assistance Advisory Bulleting and shared with the Medical Assistance Advisory Committee (MAAC) last week, the Department of Human Services (DHS) officially proposes to require both in-house and contract pharmacies to include a modifier on all Medicaid managed care drug claims. After the Dec. 22, 2022, MA Bulletin prohibiting contract pharmacies from dispensing 340B drugs was rescinded, DHS convened a workgroup with stakeholders to identify the best strategy for avoiding duplicate discounts at contract pharmacies. PACHC and FQHC representatives actively participated in these meetings and were led to believe that DHS was evaluating the options and considering the input offered and that a decision on strategy was unlikely before 2024. Consequently, the formal proposal without notification of or discussion with the workgroup came as a surprise, as was the choice of a model that is unworkable for large chain pharmacies and burdensome for in-house pharmacies. Comments on the document are due by May 4 and the proposed implementation date is July 1. PACHC will be submitting comments based on feedback from our 340B workgroup and subcommittee as well as from national 340B experts. Questions? Contact Eric Kiehl.