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THE ARC/ The Administration Goes Deeper on the 340B-to-CMS Concept
I know you all love it when we get into the 340B weeds. /s
I promise that whatever leads this newsletter tomorrow, it will not be 340B.
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I mentioned last week that the leaked draft of the president’s HHS budget proposal included a low-key bombshell: The administration was planning on moving oversight of the 340B program from HRSA to CMS.
I was basing my initial reaction on the media coverage, but the full document is now available, and there are some other interesting bits.
First, there’s this:
The idea that certain 340B entities should pass along those discounts directly is not an entirely new concept, and Trump has already proposed, in last week’s EO, the idea of making sure that health centers sell back insulin and EpiPens at the 340B price.
The budget proposal would seem to expand that to all medicines, though — again — just for health centers. There are good reasons to object to this policy for protect-the-health-centers reasons, but it suggests there’s a slippery slope here toward passing along all 340B discounts directly to patients.
First insulin at FQHCs, then all medicine at FQHC … could all medicines at all covered entities be that far behind? (I’m being wildly speculative here, but if you buy the underlying logic, it’s hard not to consider that conclusion.)
Then, there’s this:
I read at least three potentially important ideas baked into that paragraph:
More reporting/transparency, which is only going to expose clear evidence of (at best) waste and (at worst) abuse.
New standards for 340B participation, which suggest the intriguing possibility that the government would start stripping away 340B eligibility.
And there’s the bit about benefitting “low-income and uninsured patients.” The evidence is increasingly clear that the 340B program is not making a difference to those patients, and a little more government oversight there could also be revolutionary.
Here is where the giant asterisks go. The budget is an entirely symbolic document. This requires a lot more bureaucratic capacity around 340B than probably exists right now. A lot of the changes here might not fly, legally.
But as a statement of principles, this is kind of radical, no?
ON LOOP/ My Five Least Favorite Words in Biopharma
Here’s your quick shot of levity today … the words that make me shake my head. What are yours?
QUICK TURNS/ A Couple of Newsletters For You
There’s a lot floating around out there, and I won’t get to it all today. Some of that is just a matter of my time. Expect a big wrap on executive order reactions in the next couple of days. And some of it is a matter of my not amplifying journalism that I have questions about.
Here’s the rest:
This may be the best story ever written on why “alternative funding programs” are the worst idea in health care. Incredible work by Bloomberg’s John Tozzi.
My favorite newsletter edition of the week is Preston Alexander’s Healthcare Breakdown. Preston let Chris Deacon guest-post, and Chris goes deep on the trend of employees suing employers over the management of their health benefits. None of this “fiduciary” stuff is easy, but holy moly is it ever important.
My second-favorite newsletter this week is from Nikhil Krishnan’s Out of Pocket … specifically the bits at the bottom where he talks about 340B. I am here to support anyone who makes 340B-related memes. (Nikhil also asks some pointed questions about whether 340B dollars are flowing to the right hospitals, which is exactly the question to ask.)
California is making good on its pledge to sell generic Narcan for $24. That’s more than 10 bucks less than Walgreens’ generic version. I’ve been skeptical of California’s ability to truly drive drug savings, but they seem to have found a way to either create a small subsidy or drive out supply chain costs. Either way: noteworthy.
Harvard’s Jerry Avorn is one of the OG pharma skeptics. I’m going to be on the other side of most of the arguments that he makes, but it is unwise to not to consider his reach or his approaches. All of that to say: He has a new book out, and he talked to WBUR’s On Point about it in an interview that’s probably worth checking out.
Generally, SCOTUS experts are cautious about interpreting how justices think based on oral arguments. But everyone seems comfortable calling yesterday’s session a slam-dunk win for the Affordable Care Act’s preventive care mandate.
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