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This week, we are joined by Amanda Nagrotsky, 340B Health’s legal counsel. 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 what resources are available to help them navigate the process.Before the interview, we give an update on HRSA taking an enforcement action against another drug company who has refused to provide 340B discounts when drugs are dispensed at community pharmacies.  

Eligibility Requirements for 340B Child Sites.

Amanda describes lists the eligibility requirements for a hospital’s offsite facility to participate in 340B and explains why the Health Resources & Services Administration (HRSA) requires the registration of child site facilities for 340B compliance. The types of offsite facilities that need to register has changed over the years.

The Timeline for Child Site Registration.

Historically, 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 what the penalties are for making mistakes during the registration process. 340B Health also has several resources for hospitals to use as they prepare for registration. 

Check out all of our episodes on the 340B Insight podcast website. You also can stay updated on all 340B Health news and information by visiting our homepage. If you have any questions you’d like us to cover in this podcast, email us at [email protected].

Resources 

1. HRSA October 4, 2021 Letter to Boehringer Ingeleheim 
2. HHS Takes Vital Next Step Toward Ending 340B Pricing Denials
3. 340B Insight Episode 35 with Maureen Testoni
4. 340B Health Policy Guides