There are not that many core requirements within the 340B Statute. For being on its face, what appears a fairly “simple” program, it is instead turning into a mighty complicated program. One of two main requirements is “no duplicate discounts.”

A Possible Solution for Preventing Duplicate Discounts under 340B Program

There are not that many core requirements within the 340B Statute. For being on its face, what appears a fairly “simple” program, it is instead turning into a mighty complicated program. One of two main requirements is “no duplicate discounts.”

A “duplicate discount” is when a prescription (or administration) of a 340B priced outpatient drug is also subject to a pharmaceutical manufacturer’s rebate under a Medicaid program. Purchasing a drug at a discount under 340B and the claim also being subject to a rebate under a state Medicaid program would subject the manufacturer to “two” (duplicate) discounts. Filling a prescription and billing a managed Medicaid plan is allowed so long as the state is aware, so they withhold that prescription from their rebate submission to the manufacturer. The opinion of manufacturers these days is that there are “rampant” duplicate discounts being paid out.