340B Hospital Commitment to Good Stewardship Principles

In its more than three decades, the 340B Drug Pricing Program has enabled eligible hospitals that serve large numbers of low-income patients to stretch scarce federal resources and provide more comprehensive care to their patients and communities as Congress intended.

To ensure good stewardship of the 340B program, participating hospitals should structure hospital policies and practices in a way that demonstrates their commitment to the program. That demonstration of commitment includes sharing publicly how 340B savings are used to benefit the community by, for example, reaching more eligible patients and providing more comprehensive services for those in the community.

The following principles serve as the foundation for every 340B hospitals’ good stewardship of the program:

• Commitments to Good Stewardship Principles:
   
• Communicate the Value of the 340B Program: The hospital commits to preparing and publishing a narrative, on an annual basis, that describes how it uses 340B savings to benefit its community.
  • The narrative would address programs and services funded — in whole or in part — by 340B savings, including services that support community access to care which the hospital could not continue without 340B savings.
  • Examples of such programs and services will be particular for each hospital and could include programs that expand access to drugs for vulnerable populations, as well as access to a wide range of other services, such as preventive care, emergency services, cancer treatment, vaccinations, home-based care and mental and behavioral health services.
     
• Disclose Hospital’s 340B Estimated Savings: The hospital commits to publicly disclosing on an annual basis its 340B estimated savings, calculated using a standardized method.
  • That method would calculate 340B savings by comparing the 340B acquisition price to group purchasing organization pricing. If GPO pricing is not available for a 340B drug, the 340B acquisition price for a drug would be compared to another acceptable pricing source.
  • To provide context for the estimated savings, a hospital could compare its 340B estimated savings to the hospital’s total drug expenditures, as well as provide examples of its top 340B drugs.
     
• Continue Rigorous Internal Oversight: The hospital commits to continuing to conduct internal reviews to ensure that the hospital 340B program meets the Health Resources and Services Administration’s program rules and guidance.
  • Included in this effort is a commitment to regular and periodic training for the hospital’s interdisciplinary 340B teams that encompass C-Suite executives, pharmacy, legal, and financial assistance, as well as community outreach and government relations staff, if applicable.