340 B Program Where do we go from here? Christian Downs, JD, MHA Association of Community Cancer Centers

ACCC 2,200 hospitals and physician group practices across the country Multi disciplinary membership including physicians, nurses, pharmacists, social workers and administrators Main mission is advocacy and education 40 years

their oncology team members. The Association of Community Cancer Centers has 28 Chapter Members of state oncology organizations that include oncologists and their oncology team members.   The Arizona Clinical Oncology Society Minnesota Society of Clinical Oncology Association of Northern California Oncologists Missouri Oncology Society  Medical Oncology Association of Southern California Nevada Oncology Society  Rocky Mountain Oncology Society New Mexico Society of Clinical Oncology  Connecticut Oncology Association North Carolina Oncology Association*  Florida Society of Clinical Oncology Ohio Hematology Oncology Society  Hawaii Society of Clinical Oncology * Society of Rhode Island Clinical Oncologists  Illinois Medical Oncology Society * South Carolina Oncology Society*  Indiana Oncology Society * Tennessee Oncology Practice Society *  Iowa Oncology Society* Texas Society of Medical Oncology *  Louisiana Oncology Society VA Association of Hematologists & Oncologists *  Massachusetts Society of Clinical Oncologists Washington State Medical Oncology Society Michigan Society of Hematology & Oncology Kansas State Medical Oncology Society Wisconsin Society of Oncologists West Virginia Medical Oncology Society* * Managed by the Oncology State Society Network (OSSN)

Agenda Review of the 340 B program Four Major Trends What needs to be done What probably will happen At the end of the day…

340 B Program Since 1992, certain covered entities may purchase prescription drugs at a discount if they treat high numbers of uninsured indigent patients.

Oversight done by participants. 340 B Basics Since 1992, certain covered entities may purchase prescription drugs at a discount if they treat high numbers of uninsured incident patients. ---------------- Oversight done by participants.

Clarity “I am from Washington and I am here to help.” Congress has expanded access to the 340 B program. Regulators have struggled to provide clear instructions to stakeholders. Courts have limited regulators authority.

Cancer Delivery- Circa 2000 Hospitals Uninsured Not covered Expensive No services “hot mess” Offices Insured Expensive Better run Cheaper More services Patients

Cancer Delivery Hospitals Offices Uninsured Insured Not covered Expensive No services “hot mess” Offices Insured Expensive Better run Cheaper More services Patients

Stakeholders Reformers Status Quo Whoa We are paying the freight Beverly Hills Raises costs for some patients You get reimbursed more than the drug cost More of everything You charge too much for shipping Beverly Hillbillies Lowers cost for other patients Pot meet kettle

Major Trend- Payment Revolution Movement away from fee for service Bundling of payment Payment for reporting Emphasis on primary care Focus on therapies

Major Trend- Consolidation Larger and larger “systems” Hospitals purchasing hospitals Practices purchasing practices Hospitals purchasing practices Market specific Experience of other specialties

Major Trend- Integration Creating a longitudinal treatment algorithm Corporate structure Cancer treatment delivery is complex Use of data and technology Focus on therapies

Major Trend- Coverage Expansion Exchanges for individuals and small business Medicaid eligibility expansion More covered people, less covered services Nominally should reduce uninsured and indigent

What Needs to be Done… Clear, comprehensive rule about how the program shall work Carefully review the role of non-providers Identify methods to improve the program Qualify patients not providers Understand how the trends impact the program

What Probably Will Happen… HHS releases sub-regulatory guidance Congress does not move any legislation AHA and Pharma fight it out No real improvement takes place

At The End of the Day…

On behalf of our member hospitals, THANK YOU On behalf of our member hospitals, practices and our individual cancer professionals THANK YOU for your support.