Summary
This memorandum provides background on the 340B Drug Pricing Program to assist with review of the Health Resources and Services Administration (HRSA) omnibus guidance on key program parameters, released August 27, 2015. Congress has demonstrated sustained interest in the program, raising the possibility that HRSA’s highly anticipated guidance may not be the final word on these key issues. The Medicare Payment Advisory Commission (MedPAC) also continues to examine Medicare Part B drug spending at 340B hospitals, opening another front of potential 340B scrutiny and reform.