Chief Compliance and Ethics Officer Health Care

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  • 1.  340B Supreme Court Ruling

    Posted 08-11-2022 08:40 AM
    My organization purchases OP drugs under the 340B program.  In light of the recent Supreme Court ruling and the Interim OPPS rules regarding cuts CMS made to 340B drug reimbursement in 2018 to present, has any organization out there elected to now remove the JG modifier pending the final OPPS rules?

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    Renee Bullard
    Compliance Ofcr/Risk Mgr
    Magnolia Regional Hlth Ctr
    Corinth,MS
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  • 2.  RE: 340B Supreme Court Ruling

    Posted 08-11-2022 10:05 AM

    Renee,

    I reached out to our 340B administrator.  He said this was a topic that he tangentially heard being discussed at a 340B Coalition conference last week.  Because we are CAH covered entities, we are not subject to the OOPS reimbursement issues and JG modifier that DSH hospitals are, so he isn't sure what larger DSH hospitals are doing in light of the new ruling.  He felt that it seemed like most were still adding the JG modifier, but they may not have expressed their intentions to remove it.  He believes this could be an individual 'institution by institution' decision based on legal advice and documentation in their policy and procedure.

    Cinda

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  • 3.  RE: 340B Supreme Court Ruling

    Posted 08-11-2022 10:09 AM

    Thanks so much for your reply.

     

     

    Renee Bullard, CHC | Director, Compliance

     

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