According to its website, “340B ESP allows 340B covered entities and pharmaceutical manufacturers to work collaboratively to resolve duplicate discounts.” In truth, the quote-unquote “service” is nothing less than a brazen, unlawful ploy by the drug manufacturers to evade the discounts they are legally obligated to offer eligible entities — by placing extraordinary, and unnecessary, reporting burdens on hospitals submitting claims for 340B savings.

First, and this cannot be stressed highly enough, 340B ESP is not a government entity. It is an online portal operated by Second Sight Solutions — a privately owned corporation (created and run by a man with a long history of drug-industry advocacy), with no legal right to impose its restrictions on covered entities.

The reporting burdens 340B ESP place on covered entities

Under the requirements set down by Drug Manufacturers, covered entities must report, twice monthly, their covered prescriptions from every TPA with whom they work through 340B ESP. Because every TPA uses a different technology interface, this further complicates matters for already overworked covered entity employees. 

Extracting covered prescription data from some TPAs is literally impossible, due to the lack of available 340B pricing in the 340B wholesaler account. Moreover, the idea that covered entities will regain access to their 340B discounts is an illusion — as some manufacturers have placed 45-day time-frame restrictions from the dispensing of the prescription to replenishment, knowing the covered entities will not be able to meet this requirement. 

It gets even worse. The website claims prescription discounts will be issued to entities within 10 days of claims being made. Numerous reports indicate that, after periods as long as 2 to 3 months, only 50% of the manufacturers had restored 340B discounts. What’s more, entities are now forced to track their submissions, to determine whether or not they’ve been restored. For most covered entities, this involves tracking literally thousands of submissions, with thousands of different price points. 

How ProxsysRx helps eligible entities deal with 340B ESP

If you choose to report claims data to 340B ESP, we’ll report on your behalf. Then we’ll track 340B price reinstatement — by manufacturer, and by contract pharmacy. We’ll also verify 340B price availability for each manufacturer, in each wholesaler account, for each of your contract pharmacies. Once verified pricing has been restored along the entire chain, we’ll work with your TPAs to ”turn-on” replenishment — and ensure they replenish appropriately.