The Public Health Service (PHS) Double-Dip
There are other, less obvious overcharges that result in overpayments. The inadvertent double rebate to Public Health Services (PHS) is one of the most costly.
The Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services, is the primary federal agency for improving access to health care services for people who are uninsured, isolated or medically vulnerable. HRSA receives the same discount on prescription drugs as Medicaid, but they get it up front. Here’s how it works:
A PHS applies to the HRSA for 340B (discount) status. If the PHS qualifies, they purchase the drugs from a wholesaler at the discount equivalent to that calculated for Medicaid.
If the PHS dispenses drugs to a Medicaid recipient, it can submit a claim to Medicaid for reimbursement. After issuing the reimbursement, Medicaid is supposed to then use the HRSA database to exclude this claim from Medicaid rebate billing process since the product was already discounted. Unfortunately, this process doesn’t always work. Many times the 340B discount and the Medicaid rebate are applied to the same drug purchases.
Craig Rodenhizer is a leading expert on this topic. He discovered nearly $4 million in ineligible rebates for one manufacturer alone.
If you’re ready, contact TRG about your company’s rebate program.
The Rodenhizer Group, LLC.
Call (615) 812-3166 or
e-mail us.
