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“Comparing 340B University and the 340B Coalition Conference”

To Be or Not To 340B By Alyce C. Katayama and Elizabeth R. Gebarski

Maybe it is just us, but we wanted to know whether we would get a different experience at 340B University versus the 340B Coalition Conference. In some ways, these conferences could not have been more different. But, at the heart of it all, each had the same underlying education of stakeholders so that covered entities (“CEs”) can continue stretching “scarce Federal resources as far as possible, reaching more eligible patients and providing more comprehensive services.”

340B University

The 340B Prime Vendor, Apexus, puts on this educational program. Apexus is the “exclusive contractor” for the 340B Drug Pricing Program (“340B Program”). As the 340B Prime Vendor, Apexus works closely with the Health Resources and Services Administration (“HRSA”) to provide education to providers.

What 340B University Will Give You

340B University’s agenda is basic education. This program is geared towards stakeholders, primarily CEs. For example, one educational objective is that “[u]pon completion of the 340B University, participants will be able to describe the history, intent and statutory principles of the 340B program.” The first day certainly met this objective, by starting with 340B Basicsand ending with a discussion on audits, primarily why and how they are done.

New this year, 340B University delved into some of the operational weeds. For example, instructors outlined the steps in starting up as a CE subject to the GPO prohibition, including how far in advance the CE should begin negotiating contracts with split-billing software systems.

What 340B University Will Not Give You

You will hear almost zero discussion of legislative developments. And, though it boasts advice regarding compliance strategies, this advice rarely passes the most basic level. This doesn’t come as a surprise, as the University is put on by a contractor hired by HRSA. This means that 340B University may only offer what HRSA has approved. In the almost 300 slides, the proposed 340B Drug Pricing Program Omnibus Guidance (“Guidance”) was mentioned on only three slides.

340B Coalition Conference

The 340B Coalition Conference is put on by 340B Health. “340B Health is a membership organization of more than 1,100 public and private nonprofit hospitals and health systems throughout the U.S. that participate in the Public Health Service 340B drug pricing program.” 340B Health lobbies on behalf of nonprofit health systems.

What the Coalition Conference Will Give You

This is where you can expect to hear about what is coming down the pike for the 340B Program. The proposed Guidance was discussed extensively and broken down into separate lectures that addressed issues unique to various stakeholders. Here, you can expect topics to be given a pro and con discussion based on each stakeholder’s point of view. For example, the CE and manufacturer perspective were hashed out in the lecture on the implications of the proposed patient definition. This Conference also gives you the opportunity to sit in on small, group discussions specific to your position in the 340B Program.

What the Coalition Conference Will Not Give You

If basic education is what you are looking for, this is not the place. The 340B Coalition Conference offers a pre-conference basic education two-part course, but then expects attendees on the following two days to be ready to dive into the details.

Regardless of which educational program you attend, you will have the opportunity to network with like-minded individuals, all trying to find their way compliantly in this complicated space.