340B Medicaid/Duplicate Discounts

FAQ ID: 1382

Last Modified: 05/12/2023

Q: Where can I download a list of all 340B covered entity sites that carve in Medicaid fee-for-service (FFS)?

A: The list of all covered entity sites that carve in Medicaid FFS is called the Medicaid Exclusion File (MEF) and is published by HRSA each calendar quarter. The MEF can be downloaded at https://340bopais.hrsa.gov/reports.

FAQ ID: 1498

Last Modified: 08/02/2022

Q: How should we bill our Medicaid agency for fee-for-service (FFS) Medicaid when we use 340B drugs to fill Medicaid prescriptions?

A: HRSA recommends that covered entities refer to their respective state Medicaid agency drug reimbursement guidelines for applicable billing requirements. See ...
Continue Reading

FAQ ID: 1374

Last Modified: 04/08/2021

Q: May covered entities list the Medicaid provider numbers of healthcare professionals on the HRSA Medicaid Exclusion File (MEF) if that is the only billing identifier submitted on the claim?

A: A covered entity site may list a health care professional’s Medicaid provider number on the Medicaid Exclusion File (MEF) if the health care professional’s Medicaid provider number is listed as the billing provider on the Medicaid billing form (for example, box 56 or box 57 on a CMS 1450 (UB-04) cla...
Continue Reading

FAQ ID: 1546

Last Modified: 04/08/2021

Q: In the HRSA Medicaid Exclusion File (MEF), what does the “start date” and the “term date” mean? Also, when may a covered entity request a change to the information on the MEF, and when will that change be considered “live” on the 340B OPAIS?

A: The date in the “start date” column is the first date that the entity began participating in the 340B Program. The date in the “term date” column is the effective date the entity is no longer participating in the 340B Program. These dates DO NOT relate to the covered entity’s MEF determination as ca...
Continue Reading

FAQ ID: 2205

Last Modified: 04/08/2021

Q: Does HRSA expect covered entities to enter the Medicaid numbers of all 50 states to avoid duplicate discounts, or just the bordering states?

A: If a covered entity site does not plan to bill 340B drugs to a particular state Medicaid agency, it should not have the state listed on the HRSA Medicaid Exclusion File (MEF).

If a covered entity site (340B ID) answers “yes” to the following question in 340B OPAIS: “At this site, will th...
Continue Reading

FAQ ID: 4293

Last Modified: 04/08/2021

Q: Does HRSA retroactively make changes to the Medicaid Exclusion File (MEF)?

A: HRSA generally does not make retroactive changes to the quarterly MEF once it is published. On rare occasion, a technical system issue may warrant an immediate modification. If retroactive changes are necessary, HRSA will communicate this to the 340B Program stakeholders.

FAQ ID: 2042

Last Modified: 07/31/2020

Q: Absent HRSA guidance, what actions should covered entities take regarding the prevention of duplicate discounts for drugs billed to Medicaid managed care organizations (MCO)?

A: Duplicate discounts are prohibited for Medicaid FFS and MCO drugs pursuant to section 340B(a)(5)(A) of the Public Health Service Act. The data included in the Medicaid Exclusion File (MEF) applies to drugs billed under Medicaid fee-for-service (FFS). HRSA encourages covered entities to work with sta...
Continue Reading

FAQ ID: 4312

Last Modified: 07/31/2020

Q: We do not bill Medicaid FFS at all. We do, however, use 340B for these patients; does HRSA expect us to answer “yes” to its Medicaid billing question?

A: In this situation, the entity should answer “no” to the Medicaid billing question, “At this site, will the covered entity bill Medicaid fee-for-service for drugs purchased at 340B prices?”

FAQ ID: 1475

Last Modified: 07/23/2020

Q: Our entity is using 340B drugs for Medicaid patients at multiple outpatient facilities, and these patients have Medicaid eligibility in multiple states. How must we list our NPI and/or Medicaid provider numbers on the Medicaid Exclusion File to include all states in which we will use 340B drugs to bill Medicaid?

A: Covered entities are prohibited by section 340B(a)(5)(A) of the Public Health Service Act from billing 340B drugs to Medicaid if they are subject to a rebate claim by the state. Covered entities should address prevention of duplicate discounts, including state(s)’ requirements in their policies and ...
Continue Reading

FAQ ID: 1520

Last Modified: 07/23/2020

Q: A covered entity site carves in for some state Medicaid agencies and carves out for other state Medicaid agencies. How should the covered entity site reflect this on the Medicaid Exclusion File?

A: The covered entity site should have only the states and associated billing number(s) that it carves in listed on the Medicaid Exclusion File.

FAQ ID: 2104

Last Modified: 07/23/2020

Q: What do the key fields in the Medicaid Exclusion File mean?

A: The date in the “start date” column is the first date that the entity began participating in
the 340B Program. The date in the “term date” column is the effective date the entity is
no longer participating in the 340B Program. These dates DO NOT relate to the covered
entity’s MEF dete...
Continue Reading

FAQ ID: 2213

Last Modified: 07/23/2020

Q: What changes may be made to the Medicaid Exclusion File (MEF) from one quarter to the next?

A: A covered entity site can remove its 340B ID from the MEF to reflect that it will carve out all state Medicaid for the quarter. A covered entity site can add its 340B ID to the MEF to reflect that it will carve in at least one state Medicaid for the quarter. A covered entity site that carves in may ...
Continue Reading

FAQ ID: 4309

Last Modified: 07/23/2020

Q: When will covered entity sites update their 340B OPAIS records to list each state being billed for 340B drugs, and the billing number(s) listed on the bill to the state?

A: Covered entity sites will be responsible for updating their response to the modified Medicaid billing question (at this site, will the covered entity bill Medicaid fee-for-service for drugs purchased at 340B prices?) in 340B OPAIS by the end of their next annual recertification submission.

Continue Reading

FAQ ID: 4310

Last Modified: 07/23/2020

Q: If our covered entity site only bills 340B drugs to Medicaid Managed Care Organizations, how should we answer the Medicaid billing question in 340B OPAIS that is used to populate the Medicaid Exclusion File?

A: The covered entity site should answer “no” to the Medicaid billing question in 340B OPAIS. The data included in the Medicaid Exclusion File (MEF) applies to drugs billed under Medicaid fee-for-service (FFS).

Duplicate discounts are prohibited for Medicaid FFS and MCO drugs pursuant to sec...
Continue Reading

FAQ ID: 1369

Last Modified: 07/22/2020

Q: Must a covered entity submit its Medicaid provider number (MPN) or National Provider Identifier (NPI) to HRSA for inclusion on the HRSA Medicaid Exclusion File (MEF)?

A: A covered entity site must first choose whether it will bill Medicaid for 340B drugs for its Medicaid fee-for-service patients.

If a covered entity site (340B ID) answers “yes” to the following question in 340B OPAIS: “At this site, will the covered entity bill Medicaid fee-for-service fo...
Continue Reading

FAQ ID: 1388

Last Modified: 07/22/2020

Q: Can a covered entity that participates in the Prime Vendor Program and carves out Medicaid use any drug loaded to the 340B account for Medicaid patients?

A: Prime Vendor sub-ceiling pricing on covered outpatient drugs in the 340B account must be excluded from use for covered entities that carve out Medicaid. The 340B Prime Vendor Program's sub-ceiling PHS account prices are considered 340B drugs and all the same requirements apply. Other PVP contract pr...
Continue Reading

FAQ ID: 1495

Last Modified: 07/22/2020

Q: If a hospital intends to have some clinics carve in (use 340B drugs for Medicaid patients) and other clinics carve out, should each clinic get its own NPI and/or Medicaid provider number?

A: If a covered entity site (340B ID) answers “yes” to the following question in 340B OPAIS: “At this site, will the covered entity bill Medicaid fee-for-service for drugs purchased at 340B prices?” the site must also submit each Medicaid state it plans to bill and the billing number(s) it will list on...
Continue Reading

FAQ ID: 1507

Last Modified: 07/22/2020

Q: How does a covered entity change its status on the Medicaid Exclusion File?

A: A covered entity site that wishes to change its status on the Medicaid Exclusion File (MEF) must submit a change request in 340B OPAIS (available at: https://340bopais.hrsa.gov/). Note that a change request must be submitted for each applicab...
Continue Reading

FAQ ID: 1533

Last Modified: 07/22/2020

Q: How does a covered entity carve out Medicaid?

A: To carve out Medicaid, a covered entity site does not provide drugs purchased at the 340B price to Medicaid patients.

In 340B OPAIS, a covered entity site that plans to carve out Medicaid fee-for-service should answer “no” to the question, “at this site, will the covered entity bill Medi...
Continue Reading

FAQ ID: 1537

Last Modified: 07/22/2020

Q: Which Medicaid provider number and/or National Provider Identifier (NPI) should a covered entity submit to HRSA Office of Pharmacy Affairs for inclusion on the HRSA Medicaid Exclusion File (MEF)?

A: If a covered entity site (340B ID) answers “yes” to the following question in 340B OPAIS: “At this site, will the covered entity bill Medicaid fee-for-service for drugs purchased at 340B prices?” the site must also provide each Medicaid state it plans to bill and the billing number(s) it will list o...
Continue Reading

FAQ Search

Medicaid/Duplicate Discounts

How Can We Help?