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

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 carve in or carve out for Medicaid fee-for-service. To download the MEF for a specific quarter, on the MEF homepage in the 340B OPAIS a quarterly date range must be selected and those dates reflect the effective dates of the selected MEF download. Please note that the MEF only applies to Medicaid fee-for-service.

Covered entities may request a change to the 340B MEF at any time, but changes do not take effect until the 1st day of the following quarter and only if approved by OPA before the time it takes a quarterly snapshot of carve in/carve out decisions. Covered entities should time their 340B Medicaid billing practice to coincide with the first day of the quarter that reflects the new billing status. The 340B OPAIS takes a snapshot of carve in/out decisions at 12:01 a.m. ET on the 16th day of the month prior to the start of each quarter, irrespective of weekends or holidays. HRSA therefore encourages covered entities to submit carve in/carve out decisions before HRSA takes its quarterly snapshot to provide sufficient time to process and approve the request. To access the current Medicaid Exclusion File, visit "Medicaid Exclusion File."