Amid all the other news (!!) today, HRSA released the proposed rule that is the first step to implementing the EO on “Access to Affordable Lifesaving Medications,” which is designed to lower out-of-pocket costs for insulin and epinephrine at community health centers. 1/6
The proposed rule would require CHCs to provide insulin/ epinephrine at 340B price (which is often 1 penny) plus administration fee for qualifying patients <350% FPL ($92K for a family of 4) who are uninsured or who have high out-of-pocket costs for insulin or epinephrine. 2/6
CHCs are already required to provide free care (including Rx) to patients <100% FPL and to have a sliding fee scale up to 200% FPL. 3/6
If finalized, this rule could help some patients struggling to afford insulin and epinephrine – but it won’t be a silver bullet since people only qualify for the discounts if they are patients at the CHCs (just filling a script there doesn’t cut it). 4/6
CHCs and other HRSA grantees represent less than 20% of 340B sales (78% are from DSH hospitals) so this could have had a broader reach if hospitals were included. 5/6 http://medpac.gov/docs/default-source/reports/may-2015-report-to-the-congress-overview-of-the-340b-drug-pricing-program.pdf?sfvrsn=0
Also, since HRSA grants require that CHCs reinvest any money they make off of the spread between 340B acquisition cost and payment for the Rx, this policy could leave CHCs with fewer resources to help other patients struggling to afford care. 6/6