ACE Financial Management & Duplicate Discount Prevention Flashcards
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What is a duplicate discount in the 340B Drug Pricing Program?
Answer: Receiving both a 340B discounted price and a Medicaid rebate on the same drug unit
A duplicate discount occurs when a drug unit benefits from both the 340B discounted purchase price and a Medicaid manufacturer rebate, which is prohibited by the 340B statute.
Which of the following drug categories is exempt from the duplicate discount prohibition?
Answer: Drugs dispensed to Medicaid managed care patients when the state has not carved them into fee-for-service
The duplicate discount prohibition generally applies to Medicaid fee-for-service claims; drugs dispensed under Medicaid managed care may not trigger the prohibition depending on state carve-out elections.
What is a Medicaid 'carve-out' in the context of 340B duplicate discount prevention?
Answer: The state electing not to submit 340B drugs for Medicaid rebates, preventing duplicate discounts
A Medicaid carve-out means the state excludes 340B-purchased drugs from Medicaid rebate requests, thereby preventing a duplicate discount on those units.
What is a covered entity's obligation to prevent duplicate discounts for Medicaid fee-for-service claims?
Answer: Identify and exclude 340B-purchased drugs from Medicaid rebate-eligible claims or notify the state
Covered entities must implement systems to identify 340B claims and either exclude them from Medicaid rebate submissions or properly notify the state to prevent duplicate discounts.
Which system is most commonly used to prevent duplicate discounts in 340B contract pharmacy arrangements?
Answer: Split-billing software that identifies and separates 340B-eligible from non-340B claims
Split-billing software automatically separates 340B-eligible claims from non-340B claims, helping covered entities prevent duplicate discounts by tracking which drugs were purchased at 340B prices.
What is the potential consequence for a covered entity that allows duplicate discounts to occur?
Answer: Termination from the 340B program and repayment of improperly obtained discounts
Allowing duplicate discounts is a serious violation that can result in termination from the 340B program and a requirement to repay the value of the improper discounts received.