340B Contract Pharmacy Arrangements: What Does the Future Hold?

Structuring Arrangements, Meeting Legal and Regulatory Requirements

This program has been rescheduled, new date is 12/21/17

Recording of a 90-minute CLE webinar with Q&A

Conducted on Thursday, December 21, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will provide guidance to healthcare counsel on contract pharmacy arrangements and the key legal and regulatory considerations for structuring and documenting the arrangements in an uncertain regulatory environment.


CMS’ recent proposal to make significant cuts to reimbursement of Part B drugs for hospitals participating in the federal 340B Drug Discount Program has many industry observers wondering about the future of the program and about the contract pharmacy arrangements that ease many hospitals’ entry into the program.

Contract pharmacy arrangements have increased significantly since HRSA issued guidance permitting covered entities to use multiple contract pharmacies. To properly structure and document these arrangements, counsel must have a detailed understanding of the legal and business issues in contract pharmacy arrangements.

In addition, in light of the new administration and recent CMS proposals to scale back reimbursement to 340B hospitals, counsel must stay abreast of new developments.

Listen as our authoritative panel of healthcare attorneys examines contract pharmacy arrangements and the key legal and regulatory concerns when structuring and documenting the arrangements.



  1. Recent 340B developments: What is the going forward impact on 340B contract pharmacy arrangements?
  2. Structuring and implementing contract pharmacy arrangements
    1. Need for services
    2. Due diligence
    3. Fee structures
  3. 340B entity compliance issues
    1. Certifications
    2. Contractor associated liability
    3. Covered entity requirements
  4. Enforcement and sanctions


The panel will review these and other key issues:

  • What compliance challenges must be overcome when structuring a contract pharmacy arrangement?
  • With the new administration and the withdrawal of the proposed mega guidance, what does the future compliance landscape for contract pharmacy arrangements look like?
  • What operational and contractual considerations should counsel keep in mind when structuring and implementing these arrangements?


Jackson, Travis
Travis F. Jackson

King & Spalding

Mr. Jackson counsels health systems and hospitals in a wide array of areas, including pursuing mergers and...  |  Read More

Miley, Claire
Claire F. Miley

Bass Berry & Sims

As a senior healthcare regulatory and transactional attorney, Ms. Miley focuses on complex healthcare...  |  Read More

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