Reporting of 340B Ceiling Prices
This means that manufacturers will be able to report 340B Ceiling Prices directly to HRSA in the OPAIS beginning Q1 2019. This appears why HRSA finalized its proposal moving up implementation of the final civil monetary penalty rule to January 1, 2019; as we noted in May, HRSA had previously proposed delaying implementation until July 1, 2019. If you have questions about how this may affect your reporting obligations, please contact Stephanie Trunk or Erin Atkins.
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