The Key Takeaways are:
1. Given the ongoing chaos in Congress, there are growing concerns that the urgent need to provide CHCs with increased funding is "dropping off the radar screens" of many House and Senate members. This reinforces the need for a strong, grassroots advocacy effort to remind Congress of the need urgency to move on this funding soon, and why increased funding is needed. See page 3.
2. Providers will continue to be allowed to prescribe controlled substances via telehealth without first seeing the patient in-person through the end of 2024. Until last Friday, this COVID-era flexibility was scheduled to end next month. See page 6.
There are three Recommended Action Items:
1. Please do what you can to keep up the advocacy drumbeat for CHC/ NHSC/ THC funding on Capitol Hill. (If you are coming to DC for the NACHC fly-in next week, thank you in advance for that.) Other options include:
- Be on the lookout for a national call-in day, being organized by NACHC. (They are waiting until the dust settles a bit to set a date.) See page 3.
- Two recent media pieces – an editorial in the Minneapolis paper and a Health Affairs Forefront article -- might help you draft your own messaging. See page 4.
- For strategies to help keep up advocacy momentum among your CHCs, see page 4.
3. Remind your CHCs that next Monday, Nov. 16, is the last day to make the changes needed on OPAIS (HRSA's 340B database) to enable them to begin having a "single contract pharmacy" for each of their sites, as opposed to one per organization, starting around February. For more information, see these detailed instructions on how to implement this change and this (new) video demonstrating the process. See page 6.
3. Ensure that all your CHCs who provide pharmaceutical services know that they have until Monday November 27 to obtain have Global Location Numbers (GLNs) for each location where they dispense, order, and/or bill drugs to. This is a requirement of the 2013 Drug Supply Chain Security Act. While the FDA recently stated that it will not penalize providers for not having GLNs until Nov. 27, 2024, at least one major wholesaler will no longer ship or bill drugs to locations without proper GLNs starting Nov. 27 of this year (when the requirement officially goes into effect.) Wholesalers have already obtained GLNs for many of their CHC clients, so CHCs who aren't sure if they have them should start by contacting their main wholesaler. For more information, see the attachment and page 5.
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Courtney Woomer
Kentucky Primary Care Association
Frankfort KY
(502) 227-4379
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