As outlined in a HRSA Policy Release (“Clarification on Use of the Medicaid Exclusion File,” No. 2014-1), the MEF does not apply to 340B drugs that are billed under Medicaid managed care organizations (MCO). While HRSA has not established a policy for how to handle MCO drugs for purposes of prohibiting duplicate discounts, we are aware that some covered entities have already worked with MCOs and state partners to develop models for the prevention of duplicate discounts.
In addition, the Centers for Medicare & Medicaid Services (CMS) has developed an Information Bulletin (PDF - 171 KB) that describes best practices that states can use to avoid 340B duplicate discounts in Medicaid. HRSA encourages 340B covered entities to work with their state to develop strategies to prevent duplicate discounts on drugs reimbursed through MCOs.