Inconsistent Modifiers
There are several opportunities for duplicate discount payments due to lack of a 340B eligible modifier and disparate data flows. A single 340B script can trigger multiple discount/rebate payments from manufacturers
IRA Maximum Fair Price (MFP) Duplicate Payments
CMS has declined responsibility for operationally preventing or reconciling duplicate discounts between MFP and the 340B program, leaving manufacturers to manage both the process and financial exposure. Analysis of OptivanceX data suggests that 40% of MFP claims were incorrectly processed in the first month of implementation.
Operational Gaps
Core data transparency gap: no 340B modifier for Part D drugs and lack of enforcement for recently established Part B modifier. 340B Rebate Model 2.0 is likely but implementation questions persist. Current vendor platforms focus on either 340B claims recovery or processing versus providing an end-to-end solution.