A Possible Solution for Preventing Duplicate Discounts under 340B Program
There are not that many core requirements within the 340B Statute1. 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 out2.
Most 340B claims going through a contracted pharmacy are identified as "340B eligible" in a retrospective manner. This usually prevents addressing, at the time of dispensing, any designation as a "340B claim." Because of this, most 340B Covered Entities choose to block the "capture" of these claims and not replenish with 340B priced drugs. The main way to do this is by using the billing information on the claim, known as the "BIN Block" method. A BIN Block consists of a BIN (bank identification number), and a PCN (processor control number) and/or GRP (group designation). These values are attached and are transmitted on each claim record. Most BIN Block systems require a correct and accurate ("exact") match between the data in the BIN block system and the claims records to prevent the capture.
For how important the duplicate discount issue is within the 340B program, one would think more would be done to establish an efficient and accurate methodology?
The following are potential changes that could address the currently known challenges:
Access to the BIN Information
Currently, there is no central database known to the 340B Covered Entities or their administrators that contain all the Medicaid Plans' BIN combinations (as they currently exist or are modified over time.) CMS now requires Medicare Part D Plans to have "unique" BINS – why can't there be a mandate that all Medicaid Plans (FFS and MMCO) have – AND publish (e.g. make available on their websites on the landing page) – up-to-date BIN information? And require that the BIN’s be unique and dedicated solely to Medicaid plans? This would allow BIN Block systems to maintain the most up-to-date combinations which would efficiently and accurately block the capture and replenishment of unwanted Medicaid claims.
