340B Contract Pharmacy Arrangements: What Does the Future Hold?
Structuring Arrangements, Meeting Legal and Regulatory Requirements
Recording of a 90-minute CLE video webinar with Q&A
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.
Outline
- Recent 340B developments: What is the going forward impact on 340B contract pharmacy arrangements
- Structuring and implementing contract pharmacy arrangements
- HRSA essential compliance elements
- Fee structures
- Discounts for uninsured patients
- Reconciliation (including DIR Fees)
- 340B entity compliance issues
- Prohibition against diversion
- Prohibition against duplicate discounts
- Inventory management issues
- Enforcement, sanctions, and litigation
Benefits
The panel will review these and other key issues:
- What compliance challenges must be overcome when structuring a contract pharmacy arrangement?
- 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?
Faculty

Jeffrey I. Davis
Of Counsel/Senior Advisor
Baker Donelson Bearman Caldwell & Berkowitz
Mr. Davis provides clients with healthcare regulatory counsel on issues affecting healthcare providers, including... | Read More
Mr. Davis provides clients with healthcare regulatory counsel on issues affecting healthcare providers, including Medicare and Medicaid billing and reimbursement. He assists hospitals, pharmacies, other healthcare providers and vendors on issues related to the federal 340B drug pricing program, including enrollment; contracting; audits; compliance with 340B, Medicare, and Medicaid requirements; and self-disclosures. Mr. Davis also provides clients with strategic advice related to public policy issues before the U.S. Congress and the administration, including drug pricing and nonprofit hospital issues.
Close
Jesse C. Dresser
Partner
Frier Levitt
Mr. Dresser heads the firm’s Pharmacy Practice Group. In this role, his practice is dedicated to representing a... | Read More
Mr. Dresser heads the firm’s Pharmacy Practice Group. In this role, his practice is dedicated to representing a broad cross-section of pharmacies and pharmacy providers, including community retail pharmacies, chain pharmacies, compounding pharmacies, specialty pharmacies, mail order pharmacies, home infusion providers, digital pharmacies, and dispensing physician practices. Mr. Dresser represents pharmacy providers nationally regarding issues with payors and Pharmacy Benefit Managers (PBMs), including PBM audit appeals, network terminations, network access and credentialing applications, and reimbursement issues.
Close