340B Insight Podcast
Episode Thirty-Six: 340B Child Site Registration
October 12, 2021
This week, we are joined by Amanda Nagrotsky, 340B Health’s legal counsel. 340B child sites are a key component of how hospitals reach more patients and provide more health care services. Amanda discusses what hospitals need to know about registering child sites, including eligibility requirements, registration timelines, required documents, and available resources to help them navigate the process. Before the interview, we provide an update on the Health Resources & Services Administration (HRSA) initiating enforcement actions against another drug company that has stopped providing 340B discounts when drugs are dispensed at community pharmacies. (Transcript)
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- Eligibility Requirements for 340B Child Sites Amanda describes the eligibility requirements for a hospital’s offsite facility to participate in 340B and explains why HRSA requires the registration of child site facilities to ensure 340B compliance. The types of offsite facilities that need to register have changed over the years.
- The Timeline for Child Site Registration It often has taken a long time to complete child site registration. Amanda describes the timeline and how recent policy clarifications have enabled child sites to become eligible for 340B much faster.
- How Hospitals Can Prepare for Registration Amanda discusses some of the challenges 340B hospitals face registering child sites, shares which documents hospitals must prepare, and describes the penalties for making mistakes during the registration process. 340B Health also has several resources for hospitals to use as they prepare for registration.
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