To address a compliance concern regarding duplicate discounts (340B discount and Medicaid rebate on the same prescription), drug manufacturers partnered with a third-party contractor, Second Sight Solutions, to implement a system called ESP. The idea was that 340B covered entities could upload contract pharmacy claims data to ESP, and the manufacturer would evaluate this data to determine eligibility for 340B pricing. If approved, the manufacturer could then communicate this information to 340B wholesalers and restore pricing to the eligible entity.URL :https://www.proxsysrx.com/2022/08/09/340b-esp-why-its-wrong-and-how-hospitals-can-deal-with-it/
Unfortunately, what started out as a solution to a compliance issue became nothing short of a weapon in the arsenal of many drug manufacturers against 340B-eligible entities. Manufacturers have implemented a variety of blatantly unlawful restrictions through ESP and other channels that make it exponentially harder for hospitals to report contract pharmacy dispenses in the required format.
Navigating the Complexities: Strategies for Dealing with 340B ESP Challenges
The 340B ESP platform requires a health industry number, or HIN, available through GPO distributors or the manufacturer (sometimes for a fee). It also requires that all pharmacies identified in the submission are registered with the OPAIS system, and 340B ESP will use the pharmacy location (identified via IMiD) to identify a winner and load the 340B price.
This is problematic for health systems that utilize multiple TPAs or those with complex internal 340B pricing structures, because not all TPAs support OPAIS. Furthermore, it isn’t uncommon for TPAs to mismatch 340B and non-340B dispenses due to a multitude of factors. And finally, even if all 340B-eligible prescriptions are loaded into the system, some pharmaceutical manufacturers still decide that their policy is violated and require the entity to upload additional data to the ESP portal in order to have 340B prices restored.