Clearinghouse Series Part III: 340B Clearinghouses

A significant amount of legislation and discussion is underway to establish a 340B Clearinghouse. RxParadigm has published a series of articles delving into existing Clearinghouses, in both healthcare and non-healthcare industries. This article, the final in our series, explores the role of Clearinghouses in the 340B space. Learn more about how Clearinghouses contribute to industry stability, regulatory enforcement, adherence to contractual obligations and safeguard the interests of all stakeholders.

Clearinghouse Overview

As detailed in the first two articles of this series, Clearinghouses are utilized in a variety of industries. In healthcare sectors, Clearinghouses help providers manage medical claims, ensure industry-wide compliance, streamline the billing process, reduce claim denials, and accelerate reimbursements for healthcare providers. In corporate finance, a Clearinghouse serves as a financial mediator in high stakes transactions. Perhaps most widely known is the Automated Clearing House (ACH) – an electronic funds-transfer system managed by Nacha that facilitates digital transactions by processing large volumes of credit and debit transactions.

Clearinghouses are necessary tools across industries, serving as centralized third party platforms to streamline data and manage complex transactions.

Legislation Calls for 340B Clearinghouse

Two new pieces of bi-partisan legislation, the SUSTAIN 340B Act and 340B ACCESS Act call for a neutral, third-party Clearinghouse in the 340B Program.

The SUSTAIN Act focuses on establishing a clearinghouse to prevent duplicate discounts and ensure accurate accounting for 340B drugs. SUSTAIN requires the clearinghouse to contract with an independent third-party entity, with responsibilities including handling data transmission, ensuring privacy and security, facilitating accurate data submissions, and managing repayment processes related to 340B claims.

The 340B Access Act calls for a claims data clearinghouse aimed at identifying and preventing the duplication of claims for covered outpatient drugs. It mandates that the clearinghouse contract with a third-party entity to ensure compliance with non-duplication requirements and to provide relevant data to manufacturers within one year of enactment. To read more about the Sustain and Access Act, check out RxParadigm’s article: Understanding 340B Legislation.

Oregon Model – 340B Clearinghouse in Action

The state of Oregon successfully operates a retrospective rebate claims review model functioning as a data Clearinghouse. Oregon’s clearinghouse minimizes 340B duplicate discounts, which occur when the same drug receives both a 340B discount and a Medicaid rebate.

Oregon uses a state contractor to collect rebate data from covered entities (CEs). By comparing the submitted CE claims to state Medicaid data, the state contractor retrospectively flags 340B claims dispensed to MCO beneficiaries. The state contractor uses a secure web platform to analyze the claims data, retrospectively identifying and excluding 340B drugs dispensed under Medicaid.

As a result of Oregon’s Clearinghouse model, manufacturers avoid paying duplicate discounts, while CEs have a streamlined 340B reporting mechanism and secure platform. Oregon’s reporting system seamlessly blends into existing 340B pharmacy inventory systems and aligns with the Center for Medicare and Medicaid Services "Best Practices For Avoiding 340B in Medicaid”.

Oregon’s model showcases the successful implementation of a 340B date Clearinghouse on the state level. Claims are submitted by multiple stakeholders to a neutral, third-party platform. That platform accurately identifies 340B claims and eliminates the risk of receiving duplicate discounts.

Clearinghouses: The Way Forward

The diverse industries utilizing data Clearinghouse models offer evidence of the effectiveness and timeliness of a neutral 340B Clearinghouse. The ongoing legislation and successful Oregon model indicate the timely need for a centralized, neutral, 340B Clearinghouse. RxParadigm’s Tungsten+ PLUS? Clearinghouse platform meets the urgent need for an agnostic, effective solution for the future of the 340B Program.