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AAMC Submits Comments to OMB on Collecting 340B Drug Cost Data

March 13, 2020

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Mary Mullaney, Director, Hospital Payment Policies

The AAMC submitted comments on March 9 to the Office of Budget and Management (OMB) asking the agency to deny a request by Centers for Medicare & Medicaid Services (CMS) for a document identifier to collect acquisition cost data for specified outpatient drugs acquired under the 340B Drug Pricing Program. 

In the response to CMS’ proposal to collect the information [see Washington Highlights, December 5, 2019], the AAMC stated it does not believe the agency has the authority to target data collection at hospitals participating in the 340B program. The letter asks that OMB not provide a document identifier to the CMS request. 

The AAMC also stated that CMS has grossly underestimated the expenditure of time and resources that hospitals will incur to collect and submit the data. The AAMC maintains that hospitals will likely be forced to redirect financial resources to comply with this and other requirements related to the survey.

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