340B Health Proposed Mega Guidance Tool

September 9, 2015

Worksheet 8

Proposed Mega Guidance Tool – Worksheet 8

Physician-Administered Drugs
Many hospitals use 340B for physician-administered drugs, such as infusion products, that are administered to individuals in the hospital or a registered infusion clinic but are written outside the hospital (by a non-hospital or a hospital provider). It appears that the guidance would limit 340B use for physician-administered drugs to situations where the order was written by a hospital provider as a result of an outpatient service provided at the hospital.
This worksheet only applies if you are currently using 340B to fill physician-administered drug orders written in connection with care provided outside the hospital and its child sites.
If Drugs Purchased
at GPO Pricing ($) / I Drugs Purchased
at WAC Pricing ($)
(for hospitals subject
to the GPO exclusion)
When estimating lost 340B savings or revenue as a result of this proposed change, keep in mind that hospitals subject to the GPO exclusion may be able to use GPO drugs in an offsite clinic if the clinic is not registered as participating in 340B and it purchases all its drugs through a separate GPO account.
Lost 340B Savings/Revenue Over Most Recent 12-Month Period ($)
Implementation and Operational Costs Over 12-Month Period ($)
Operational Challenges
Other Challenges/Concerns
Any Positive or Negative Impact on Patients?
Impact on Hospital’s Ability to Treat Vulnerable Patients
Other ways your hospital uses 340B that could be called into question by this proposed change and the impact it would have
Would the proposed change be so detrimental that your facility would consider getting out of the 340B program?

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