Policy Position

CHA Submits Comments on 340B Proposed Rule

Children’s Hospital Association sent a comment letter to the Centers for Medicare and Medicaid Services on the 340B remedy proposed rule.

Published Oct. 16, 2023|
Download

CHA sent a comment letter to the Centers for Medicare and Medicaid Services (CMS) on a proposed rule that would repay hospitals for underpayments for 340B outpatient drugs from 2018 to 2022 under the Outpatient Prospective Payment System. In addition to making one lump-sum payment to affected 340B hospitals, CMS would also recoup funds from hospitals that received increased rates for non-drug services with a prospective 0.5% cut over the next 16 years. Children’s hospitals would be subject to the 0.5% cut. Our comments oppose the budget neutrality adjustment and urge CMS to consider the unique implications for pediatric care.

Related Content

A Roadmap for Reducing Pediatric Mental Health Boarding

Pediatric mental health boarding is a system challenge. States have the power to change it.

Oct. 19, 2026

CHA Submits Comments in Response to Medicaid Provider Tax Proposed Rule

The comments urge CMS to preserve the state financing flexibility necessary to ensure children nationwide continue to have access to high quality, specialized pediatric care.

Oct. 12, 2026

What’s at Stake: Sites Aren’t Neutral for Kids

Proposed changes to site-neutral payments would threaten children’s health care.

Oct. 08, 2026

A Roadmap for Reducing Pediatric Mental Health Boarding

Pediatric mental health boarding is a system challenge. States have the power to change it.

Oct. 19, 2026

CHA Submits Comments in Response to Medicaid Provider Tax Proposed Rule

The comments urge CMS to preserve the state financing flexibility necessary to ensure children nationwide continue to have access to high quality, specialized pediatric care.

Oct. 12, 2026

What’s at Stake: Sites Aren’t Neutral for Kids

Proposed changes to site-neutral payments would threaten children’s health care.

Oct. 08, 2026