Don’t Get WAC’ed by
The GPO Prohibition



By: Michael Cook, PharmD

Strategies to Maximize 340B Savings While Optimizing Compliance

In order for disproportionate share hospitals (DSH), children’s hospitals (PED), and free-standing cancer hospitals (CAN) to participate in the 340B Program, entities must attest they will not “obtain covered outpatient drugs through a group purchasing organization or other group purchasing arrangement.” This is known as the Group Purchasing Organization (GPO) Prohibition. This means that when a hospital subject to this provision acquires an outpatient covered drug that does not qualify for 340B, it must be purchased at WAC pricing. Since this price is significantly more, there are financial implications and potential challenges to ensuring compliance within a hospital.

We have pulled together some strategies to help entities subject to the GPO prohibition maximize 340B savings while optimizing compliance.

Pre-Order Strategies

  1. Categorize drugs solely for inpatient and outpatient and purchase from separate accounts.
  2. Order NDCs that do not meet the definition of a “covered outpatient drug” through GPO account.
  3. Maintain CDM-to-NDC crosswalk or NDC-to-NDC accumulations.
  4. Load Apexus sub-WAC and individual contracts to your WAC wholesaler account as an additional layer of protection against large losses.

Order Strategies

  1. Identify items purchased via the WAC account through the split-billing software.
  2. Review orders for items that should have accumulation.

Post-Order Strategies

  1. Determine which WAC purchases lost the most savings.
  2. Monitor the WAC Impact Percentage.

There are several strategies you can take to maximize your 340B savings while optimizing compliance. Download the whole guide here for more details on each strategy.

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