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340B 'Double Dipping' Guidance Complicates Compliance, Lawyers Say

This article was originally published in The Pink Sheet Daily

Executive Summary

Long-awaited 'mega-guidance' on the 340B drug discount program addresses the statutory bar against billing manufacturers for Medicaid rebates on drugs already discounted under 340B, but the provisions relating to Medicaid managed care seem to be a 'head scratcher.'

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