The AHA July 14 urged the Health Resources and Services Administration to revise its estimate of the administrative burden associated with the agency’s proposed 340B rebate model pilot program, saying the agency’s projection of five hours of work per week significantly understates the real-world costs hospitals would face.

In comments submitted on a proposed information collection request, the AHA said HRSA’s analysis relies on the flawed assumption that hospitals can easily access and submit the data required for the rebate model because the information is already collected for billing and reimbursement purposes. The AHA said the required data are often housed in different systems, must be combined and validated before submission, and would require substantial new investments in staff time, technology and training.

“HRSA’s 5-hour estimate understates the work required to submit the information that will be required under the Rebate Program,” the AHA said. The association added that hospitals, not drug companies, are best positioned to understand the operational burdens of the proposal and that their estimates should carry greater weight.

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