340B Policy Principles & Priorities

Advocates for Community Health envisions a 340B program that works exactly as it was designed, remaining a viable resource for health centers to care for vulnerable patients.

This is why we created 340C, an “opt-in” legislative proposal designed to protect the 340B program for health centers.

The current reach of the Community Health Center Program would not be possible without the 340B Drug Discount Program. Data has shown that health centers’ grants and payer reimbursements consistently fail to cover the cost of the comprehensive services provided in the CHC environment. In fact, when Congress created the 340B program in 1992, they recognized this reality – that the 340B drug pricing program would allow safety net providers to “stretch scarce federal resources as far as possible, reaching more eligible patients and providing more comprehensive services.”

By allowing the purchase of drugs at a discounted price, the 340B program enables health centers and other covered entities to funnel the resulting savings into serving more patients with highly complex clinical and social needs than they otherwise could. In today’s economic environment, health centers depend on the 340B program to meet their mission, putting every dollar received back into the communities they serve.

We envision a 340B program that works exactly as it was designed: to stretch scarce federal resources in support of access to care for underserved patients and their communities. This vital program must be fortified so it can remain a resource for community health centers for years to come.

Read our 340C draft legislation text

Our 340B Policy Principles

Health centers’ ability to access and leverage the 340B Program is decreasing by the day, and time is of the essence. The 340B program is being steadily eroded by the actions of state policymakers, pharmaceutical companies, and pharmacy benefit managers (PBMs), to the detriment of the nation’s safety net providers.

Our 340B Policy Priorities

Advocates for Community Health supports reform of the 340B program that allows CHCs to use the program as it was intended. We urge Congress to enact the “340C” proposal to ensure that the 340B program can continue to serve as a critical resource for health centers for years to come. 340C balances the need for transparency with the need for protections from actions that are eroding the program. 340C would be “opt-in” and available to all covered entities.

FQHCs, Medicaid, and State 340B Savings “Carve Outs”:

  • CMS should exempt FQHCs from the actual acquisition cost fee for service Medicaid reimbursement methodology and instill additional guardrails around forced “carve-out” policies.
  • CMS should clarify that states are not permitted to mandate that Medicaid Managed Care Organizations (MCOs) reimburse for 340B drugs at actual acquisition cost or force providers to carve out.

HRSA should establish new requirements around entity burden reduction before approving manufacturer audits of FQHCs.

Learn more about our 340C proposal.

Read our draft legislation text.

Committed to community, with a visionary and innovative approach, our membership is leading the way in shaping the rapidly evolving health care landscape of the future. Learn more about our other policy priorities and our advocacy efforts.
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