Articles and Blogs

In an important development for 340B participating providers (“Covered Entities”), the Department of Health and Human Services (“HHS”) Office of General Counsel (“OGC”) published an Advisory Opinion stating its view that drug manufacturers must honor 340B program discounts under contract pharmacy arrangements. The Advisory Opinion was remarkable in the clarity and forcefulness of HHS’s... READ MORE

Based on recent interactions Hall Render has had with HRSA Office of Pharmacy Affairs (“OPA”) representatives, hospitals participating in the 340B drug discount program as covered entities (“Covered Entities”) may now be able to consider patients 340B-eligible in new locations of the hospital outside of the four walls of the hospital building even if... READ MORE