In the midst of the ongoing federal conversation surrounding the 340B Drug Pricing Program, individual states are implementing a number of regulatory efforts related to the 340B Program at an increasingly fast pace. These efforts are largely designed to avoid duplicate discounts, capture Medicaid drug rebates, and reduce reimbursement for 340B drugs. Many states have implemented new requirements at the claims level, though requirements widely vary by state and may vary by setting and whether billed as retail, clinic-administered, or contract pharmacy drugs.

In this episode, Richard Church and Ryan Severson discuss several specific examples of states that are implementing changes to 340B billing procedures and some of the operational and compliance challenges that may arise, particularly for providers enrolled in multiple state Medicaid programs.

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