TAPP Submits Official Comments to Health Resources and Services Administration, supporting 340B Rebate Pilot Program

The Trade Alliance to Promote Prosperity recently submitted comments to the Health Resources and Services Administration (HRSA), supporting a proposed 340B rebate pilot program.

In part, TAPP wrote, “We applaud the Health Resources and Services Administration (HRSA) for implementing this pilot program; it is a positive step toward addressing abuse of the 340B program. Yet we also urge the HRSA to take additional steps to cover all medicines and to address broader 340B program implementation concerns.”

Additionally, TAPP wrote:

…[W]e are especially concerned with the ways in which the 340B program distorts the U.S. healthcare market and ultimately hinders American scientists from helping the United States to maintain its leadership position in biopharmaceutical innovation.

The United States assumed the world leadership position in biopharmaceutical innovation in the late 1990s; now, the United States poised to sabotage its own leadership position through bad policy decisions, while China, which is already closing the gap with a surge of new drug approvals, is poised to lead.

U.S. policymakers should scrutinize bureaucratic excesses and mandates, including the 340B program, that hinder innovation while failing to provide drug cost relief to American patients. Policymakers must reject any policy that would impede private companies’ ability to engage in biomedical research and to serve American patients as effectively as possible.,,

The manufacturer rebate paradigm is one that has been used in other federal programs for decades, and it is an effective model for preventing duplicative discounts. If the goal is to lower drug prices for Americans, then Congress and the administration must fix the 340B program. Expanding this rebate model would be a good start.,,

Policymakers should pursue reforms that include oversight and transparency, requiring hospitals and pharmacies to report exactly how much revenue they generate from the 340B program and exactly how much of that money is used to provide prescription drug discounts to patients like the original law intended. Covered entities should be required to provide detailed annual reporting on how 340B revenue is used to ensure direct savings for patients. This would provide a more transparent link between program savings and patient benefits.

Also, covered entities should be required to define who a 340B patient is; they should also be required to notify patients who are designated as 340B patients and to specify exactly what discounts they should expect as 340B patients.

Read the full comments that TAPP submitted to HRSA here.