At a time when 340B hospitals are providing vital services to their communities in the wake of COVID-19, facing budgetary shortfalls and making critical staffing decisions, CMS has released its survey of average 340B acquisition costs for hospitals paid under OPPS.  CMS notes that the average time to complete the survey will be 48 hours per provider with a due date of May 15, 2020.  The survey is required for any hospital (excluding Critical Access Hospitals) that was enrolled in the 340B Program in the last quarter of 2018 and/or the first quarter of 2019.

The survey applies to specified covered outpatient drugs which are included in the Excel survey provided by CMS.  Providers may choose to allow CMS to utilize the 340B ceiling prices obtained from HRSA as a “quick survey” option to reduce the burden on the provider.  This results in a completed survey upon electing this option.

It is important to note that this survey may be CMS’ attempt to justify its cuts to separately payable 340B-purchased drugs in the 2018 – 2020 OPPS Final Rules.  Therefore, it is likely that the 2021 OPPS proposed rule will be based on the results of this survey and also used in CMS’ appeals to rulings against CMS on its prior cuts.

The survey and instructions may be downloaded here. Completing the survey, as noted in the instructions, will require submission in the website set up by CMS.

If you need assistance in completing the survey or have questions about the quick survey option, please contact us at 340B@draffin-tucker.com.

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