Avoid These Six Common Errors When Reporting 340B-Eligible Prescriptions Through 340B ESP

As we noted in a previous post, 340B ESP is nothing less than a brazen and (in our opinion) 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. 

That said, until Congress and/or the courts step-up and give HRSA the legal authority it should have to enforce the regulations established by Congress in 1992, eligible entities seeking to maximize 340B savings and revenue will continue being, for all practical purposes, strongarmed into reporting a significant percentage of their eligible prescriptions through the 340B ESP website. 

Below are six of the most common errors made by entities in reporting 340B-eligible prescriptions — and our advice for avoiding them.

1. Uploading Excessive 340B Data 

Never upload more data than is absolutely necessary, and required, by 340B ESP. Why? The 340B ESP website is operated by Second Sight Solutions — a privately owned corporation created and run by a man with a long history of drug-industry advocacy*. Moreover, under the website’s Terms Of Use, Second Site can, and will, use the non-required data you submit, to influence even more manufacturers to require data submission through the 340B ESP website.

2. Trusting 340B ESP to Restore Prices On Its Promised Scheduling

Don’t ever assume that 340B prices are restored in your contract pharmacies’ 340B wholesaler accounts by the 10-day post-submission mark (the time frame 340B ESP says to allow). 

3. Trusting 340B ESP Price Restoration, Period

When dealing with 340B ESP, never assume that any 340B price restoration you have will actually be honored. If any manufacturer working with 340B ESP decides, unilaterally, that the purchases made for any of your contract pharmacies are more than the dispenses, they’ll refuse to pay the wholesaler’s chargeback. Which will result in a credit-rebill — which results in you, the covered entity, paying WAC — which is a much higher price. 

4. Assuming Submitted Eligible Dispenses Result In 340B Price Access

Eligible 340B dispenses often do not occur in full-package-size increments. It may take months, and multiple claims, to equal a full reorderable package size. But some manufacturers will not allow 340B purchases past 45 or 60 days from dispense. Which means covered entities will likely never be able to get many of the 340B prices they are entitled to. 

5. Counting-On 340B ESP-Compatibility In Your TPAs’ Reports

When you submit your own reporting to 340B ESP, you can’t simply pull reports from your TPAs and upload them. Not without making significant modifications. 

6. Counting-On Support From 340B ESP

At the very top of the 340B ESP home page, you’ll find an email address — support@340besp.com. Don’t waste your time. 

In our experience, nobody working with 340B ESP — or the manufacturers — will help you when you don’t receive the 340B prices to which you’re entitled, even if months have passed since your first data submission. 

The Good News About 340B ESP, For Covered Entities

Despite the outrageous demands imposed on eligible entities by 340B ESP and other manufacturer restrictions, ProxsysRx has generated $135 million in 340B savings and revenues for the health systems we serve — most of that since the advent of manufacturer restrictions.

ProxsysRx is here to help, if you have questions. 

There are so many ways to optimize your health system’s 340B drug program savings and benefits, while minimizing the likelihood of noncompliance. For more information, contact Howard Hall.

C: 205.588.0946 | howard.hall@proxsysrx.com