Revised 21 May 2018
The extent to which 340B covered entities receive duplicate discounts from pharmaceutical manufacturers who participate in the Medicaid Drug Rebate Program (MDRP) is widely documented.
The Medicaid Exclusion File
The Health Resources and Services Administration (HRSA) established the 340B Medicaid Exclusion File (MEF) as The mechanism to assist 340B covered entities and states in the prevention of duplicate discounts for drugs subject to Medicaid rebates.
But in terms of efficacy, the MEF is insufficient in mitigating duplicate discounts. An estimated $2 billion in improper rebate payments are made by pharmaceutical manufacturers — and received by 340B covered entities — on an annual basis.