The Fight Over Rebates Heats Up

Intro [00:00:04]: Welcome to 340B Insight from 340B Health. David Glendinning [00:00:11]: Hello from Washington, D.C. and welcome back to 340B David Glendinning [00:00:15]: Insight, the podcast about the 340B drug pricing program. David Glendinning [00:00:19]: I'm your host David Glendinning with 340B Health. David Glendinning [00:00:23]: Our guest today is 340B Health President and CEO David Glendinning [00:00:26]: Maureen Testoni. We speak with Maureen regularly David Glendinning [00:00:30]: and wanted to have her back on the show to give us a year end David Glendinning [00:00:34]: wrap up of all the developments in the 340B world. David Glendinning [00:00:38]: So here's that conversation. Today we David Glendinning [00:00:41]: are speaking again with 340B Health President and CEO David Glendinning [00:00:45]: Maureen Testoni. Maureen, thank you for making the time to David Glendinning [00:00:49]: be with us. And welcome back to 340B Insight. Maureen Testoni [00:00:52]: Thank you, David. I really appreciate the opportunity. David Glendinning [00:00:54]: It is December now, believe it or not, and you were David Glendinning [00:00:58]: last on the show in late September. What has been David Glendinning [00:01:02]: happening in 340B since then? Maureen Testoni [00:01:04]: I think the biggest issue in 340B has been a number Maureen Testoni [00:01:07]: of drug maker proposals to turn Maureen Testoni [00:01:10]: 340B into a rebate. Other issues Maureen Testoni [00:01:14]: are that we're really focusing on are litigation Maureen Testoni [00:01:17]: around state contract pharmacy laws. There Maureen Testoni [00:01:20]: was also the first release of its Maureen Testoni [00:01:24]: kind by a state that had Maureen Testoni [00:01:27]: imposed certain reporting requirements on 340B hospitals. Maureen Testoni [00:01:31]: And that is something else that's new and I think Maureen Testoni [00:01:35]: important to understand. David Glendinning [00:01:38]: Let's start with the rebates. As I know that's been such a big deal David Glendinning [00:01:41]: for the 340B community and you just called it the number one concern at this David Glendinning [00:01:45]: point. Listeners of the show will know that Johnson and David Glendinning [00:01:49]: Johnson paused implementation of its rebate model David Glendinning [00:01:52]: after HRSA threatened strong enforcement actions. What David Glendinning [00:01:56]: is the latest on that issue? Maureen Testoni [00:01:58]: Johnson and Johnson has now sued hrsa. They're essentially saying that Maureen Testoni [00:02:01]: HRSA does not have the authority to block a rebate model. Maureen Testoni [00:02:05]: And since then, we're also seeing three other Maureen Testoni [00:02:08]: manufacturers come out saying that they Maureen Testoni [00:02:12]: want to do a rebate proposal. Bristol Myers, Maureen Testoni [00:02:16]: Squibb and Lilly have also sued Maureen Testoni [00:02:19]: HRSA, saying that they don't have authority to stop Maureen Testoni [00:02:23]: a rebate model. And both manufacturers want to impose a rebate Maureen Testoni [00:02:27]: model. And then Sanofi announced that it Maureen Testoni [00:02:30]: was going to go forward and impose a rebate model effective Maureen Testoni [00:02:35]: January 6th. So we'll see if Maureen Testoni [00:02:38]: that goes forward there. But that is something that is obviously very concerning Maureen Testoni [00:02:42]: because of the short date. David Glendinning [00:02:46]: And let's talk about some of the concerns that the David Glendinning [00:02:50]: 340B community has. What are some of those main concerns about David Glendinning [00:02:53]: 340B rebates when it comes to hospitals? Maureen Testoni [00:02:57]: Well, sticking with Sanofi, you know, they were, Maureen Testoni [00:03:01]: Sanofi was very explicit about Maureen Testoni [00:03:04]: the rules that they're gonna oppose before they would Maureen Testoni [00:03:07]: approve a 340B rebate for a drug. And it's Maureen Testoni [00:03:11]: very concerning because what Sanofi is saying is that we're gonna Maureen Testoni [00:03:15]: impose our own as to which Maureen Testoni [00:03:18]: individuals 340B hospitals can deem to Maureen Testoni [00:03:22]: be to qualify for 340B. And the rules that they're Maureen Testoni [00:03:25]: imposing are clearly intended to reduce Maureen Testoni [00:03:29]: the number of patients that hospitals can consider to be patients Maureen Testoni [00:03:33]: for 340B purposes. So this would essentially reduce the Maureen Testoni [00:03:37]: number of drugs that the company would have to offer a 340b Maureen Testoni [00:03:41]: discount on. Some of the things that they are Maureen Testoni [00:03:44]: doing is they are requiring Maureen Testoni [00:03:47]: that patients have been seen at the covered entity Maureen Testoni [00:03:51]: within two years. That is a rule that does not Maureen Testoni [00:03:55]: exist anywhere under HRSA's compliance Maureen Testoni [00:03:58]: policies. They are requiring that the Maureen Testoni [00:04:02]: prescription be directly linked to the type Maureen Testoni [00:04:06]: of medical care, to an actual service that the individual has Maureen Testoni [00:04:10]: received at the covered entity. And yet we Maureen Testoni [00:04:14]: all know that under 340 rules Maureen Testoni [00:04:18]: there can be follow up care, there can be referrals, referrals. Maureen Testoni [00:04:21]: HRSA does not make that tight a limit as to when Maureen Testoni [00:04:24]: 340B can be used. They have Maureen Testoni [00:04:28]: rules around hospitals only using Maureen Testoni [00:04:32]: prescribers that are employed by the hospital or Maureen Testoni [00:04:37]: have some other type of affiliation which is really not spelled out what Maureen Testoni [00:04:40]: that affiliation would need to look like. They're requiring various Maureen Testoni [00:04:44]: types of patient encounter data to be able to make some of Maureen Testoni [00:04:48]: these determinations. And that is just Maureen Testoni [00:04:51]: very concerning that they would try to impose Maureen Testoni [00:04:55]: their own rules like this under a rebate program. Maureen Testoni [00:04:59]: And I think that's a big concern that hospitals have. David Glendinning [00:05:02]: And I will mention that there's no public response to the David Glendinning [00:05:06]: Sanofi plan from HRSA yet and no lawsuit from the company though, that David Glendinning [00:05:09]: says of when we are speaking today. We know things can change quickly in David Glendinning [00:05:13]: this area. So that covers Sanofi. What do we know at this point David Glendinning [00:05:17]: about the other rebate models that drug makers David Glendinning [00:05:21]: are pushing? Maureen Testoni [00:05:22]: We don't have a lot of details really on the other rebate models. Maureen Testoni [00:05:25]: We know that Johnson and Johnson plan to use the same Maureen Testoni [00:05:29]: vendor, Beacon, for processing its Maureen Testoni [00:05:32]: rebates. So they do have information on the types of claims, Maureen Testoni [00:05:36]: some of the claims data that they're looking for, but they don't really Maureen Testoni [00:05:40]: provide all the details as to how they're going Maureen Testoni [00:05:44]: to use that information to determine whether to approve Maureen Testoni [00:05:47]: a claim. They just say we're going to get this data Maureen Testoni [00:05:51]: and we will then determine whether to approve. But they're Maureen Testoni [00:05:55]: not really saying what you would have to show for sure Maureen Testoni [00:06:00]: to make sure that your claim would be approved. That's a distinction Maureen Testoni [00:06:03]: with Sanofi going into a lot more detail about the new rules Maureen Testoni [00:06:07]: that they are imposing. Similarly with Maureen Testoni [00:06:11]: Lilly and with Bristol Myers Scopes. We don't Maureen Testoni [00:06:14]: know exactly what the rules are that they are proposing. Maureen Testoni [00:06:18]: And that is obviously concerning for hospitals because now Maureen Testoni [00:06:22]: if rebates were to go forward, it's all in the hands of the Maureen Testoni [00:06:25]: manufacturers as to whether and when you would receive the Maureen Testoni [00:06:29]: 340B discount that you know you are supposed to be getting that they are obligated Maureen Testoni [00:06:33]: to provide you under the 340B statute. David Glendinning [00:06:35]: Why are drug companies saying they need to impose David Glendinning [00:06:39]: rebates on 340B hospitals? What reasons are they giving in all of David Glendinning [00:06:43]: these notices and lawsuits they've been filing? Maureen Testoni [00:06:45]: Manufacturers have been claiming that 340B has grown, you Maureen Testoni [00:06:49]: know, beyond what it is supposed to grow. So they are concerned Maureen Testoni [00:06:53]: about the fact that a high number of their drugs are being subject to Maureen Testoni [00:06:57]: 340B discounts than there were in 1992 when Maureen Testoni [00:07:00]: 340B was enacted. But the truth is Maureen Testoni [00:07:04]: healthcare has moved from the inpatient setting in the hospital to the Maureen Testoni [00:07:07]: outpatient setting. So many more drugs are available in the Maureen Testoni [00:07:11]: outpatient setting than there were in 1992. And, you Maureen Testoni [00:07:15]: know, we have, you know, people aren't necessarily even getting certain heart Maureen Testoni [00:07:18]: surgeries anymore because they can rely on certain specialty drugs Maureen Testoni [00:07:22]: to address that. So it's not a surprise they are also claiming Maureen Testoni [00:07:26]: that three 340B covered entities are not always following the rules Maureen Testoni [00:07:30]: around 340B and that they believe, you know, Maureen Testoni [00:07:33]: HRSA isn't doing a good job with that. Maureen Testoni [00:07:37]: And that's, you know, you can see this with, especially with the types of rules Maureen Testoni [00:07:40]: that Sanofi is trying to put into place around, you know, Maureen Testoni [00:07:44]: does the individual patient really qualify for Maureen Testoni [00:07:48]: 340B? But the truth is, you, the Maureen Testoni [00:07:51]: Sanofi does not going to be able to figure that out. You know, this is Maureen Testoni [00:07:55]: something you have to look at medical charts. When HRSA goes in and audits Maureen Testoni [00:07:59]: covered entities, they are looking at the Maureen Testoni [00:08:02]: charts, at the patient charts to make that determination as Maureen Testoni [00:08:06]: to whether the hospitals are appropriately using Maureen Testoni [00:08:09]: 340B for the right kinds of patients. And in recent Maureen Testoni [00:08:13]: years, we're seeing findings in that area against Maureen Testoni [00:08:17]: hospitals to be very, very low. So there is just no Maureen Testoni [00:08:20]: evidence of widespread abuse by Maureen Testoni [00:08:24]: hospitals in the area of whether or not patients really Maureen Testoni [00:08:28]: qualify for 340 B. And another issue that they bring up Maureen Testoni [00:08:31]: is something that's called a duplicate discount. It's a little Maureen Testoni [00:08:35]: confusing. It means that if an entity Maureen Testoni [00:08:39]: buys a drug at the 340b price, then the Medicaid Maureen Testoni [00:08:42]: agency should not be requesting a Maureen Testoni [00:08:46]: rebate from the manufacturer for that drug. And when Maureen Testoni [00:08:50]: you look at the findings from HRSA audits, there is Maureen Testoni [00:08:54]: nothing in any of those findings to suggest that there's widespread Maureen Testoni [00:08:58]: duplicate discounts going on. Because the fact is, HRSA Maureen Testoni [00:09:02]: does not check to see whether or not a Maureen Testoni [00:09:06]: state actually sought a rebate and whether or not Maureen Testoni [00:09:09]: the manufacturer actually paid it for a 340B drug. The Maureen Testoni [00:09:13]: only thing that HRSA does when they go into their Maureen Testoni [00:09:17]: audit is identify whether the hospital Maureen Testoni [00:09:21]: complied with duplicate discount requirements. And those Maureen Testoni [00:09:24]: requirements are that the hospital has to put his billing number up on Maureen Testoni [00:09:28]: HRSA's website. And that way states can use that billing number to Maureen Testoni [00:09:32]: make, to exclude any of the drug claims that Maureen Testoni [00:09:36]: are for Medicaid patients. So hospitals, Maureen Testoni [00:09:40]: you know, if they transpose, you know, a couple of numbers in Maureen Testoni [00:09:44]: their, when they put it up on the website, they'll get a finding that says Maureen Testoni [00:09:46]: duplicate discounts. And in fact, many hospitals are able Maureen Testoni [00:09:50]: to get the duplicate discount finding change to, you Maureen Testoni [00:09:54]: know, a web site error finding because they're able to get their Maureen Testoni [00:09:57]: Medicaid agency to say, no, we don't even use HRSA's website. We have our Maureen Testoni [00:10:01]: own process for identifying 340B claims, Maureen Testoni [00:10:05]: and we can confirm we have not made any requests to the manufacturers for Maureen Testoni [00:10:08]: rebates on this entity's claims. So when we're seeing Maureen Testoni [00:10:12]: findings made by the government on duplicate discounts, it's really important to understand Maureen Testoni [00:10:16]: that does not in any way, shape or form mean that a duplicate discount actually Maureen Testoni [00:10:20]: occurred. And we have not seen real data Maureen Testoni [00:10:23]: produced by these manufacturers to demonstrate that, Maureen Testoni [00:10:27]: that this is actually a serious issue. David Glendinning [00:10:30]: Our listeners will be eager to know where this whole David Glendinning [00:10:34]: rebate debate leads for them. So what is David Glendinning [00:10:37]: 340B Health doing to advocate against these rebates? Maureen Testoni [00:10:41]: One, now that it's in the federal courts, we will again be Maureen Testoni [00:10:45]: very involved with the litigation. In previous litigation Maureen Testoni [00:10:49]: that has been filed by manufacturers against the government, Maureen Testoni [00:10:52]: we have always submitted amicus briefs, Maureen Testoni [00:10:56]: sometimes on our own, sometimes we work with other associations. So we Maureen Testoni [00:11:00]: are currently in discussions with our legal counsel to determine the best Maureen Testoni [00:11:04]: way to interact in these cases, whether Maureen Testoni [00:11:07]: it is by actually intervening, which would, if we got permission to Maureen Testoni [00:11:11]: intervene, that would allow us to make arguments directly Maureen Testoni [00:11:15]: to the judge. So it gives us a little bit more of a presence Maureen Testoni [00:11:19]: than an amicus. However, I will mention this is Maureen Testoni [00:11:22]: likely to take a While this is unlikely to be a fast moving Maureen Testoni [00:11:26]: lawsuit, so there is, you know, there still is some time Maureen Testoni [00:11:30]: before the court is really going to require any briefing on this Maureen Testoni [00:11:34]: case. You know, I will also mention that the ira, Maureen Testoni [00:11:38]: the legislation about that includes provisions to allow Maureen Testoni [00:11:41]: Medicare to negotiate lower prices for drug is going Maureen Testoni [00:11:45]: to be implemented in, you know, in the coming year. Maureen Testoni [00:11:49]: And manufacturers are going to be submitting within a few months their Maureen Testoni [00:11:52]: plans for implementing how they're Maureen Testoni [00:11:56]: going to make the Medicare prices available. And Maureen Testoni [00:12:00]: it's been controversial as to how 340 Maureen Testoni [00:12:04]: is going to fit into that. Covered entities Maureen Testoni [00:12:08]: are entitled to the 340b price regardless of what the Maureen Testoni [00:12:11]: Medicare price is. But the process that the government Maureen Testoni [00:12:15]: is using to implement it does conflict with Maureen Testoni [00:12:18]: 340B in some ways. It is absolutely Maureen Testoni [00:12:22]: doable to do what the government is proposing. But the Maureen Testoni [00:12:25]: manufacturers believe that it is having a Maureen Testoni [00:12:29]: rebate program would make it easier for them to Maureen Testoni [00:12:32]: comply with the, with the government's, you Maureen Testoni [00:12:36]: know, process. So I think it's important that we Maureen Testoni [00:12:39]: have a lot of advocacy going on about the fact this is not Maureen Testoni [00:12:43]: needed. Rebates are not needed for the IRA as Maureen Testoni [00:12:47]: well. I wrote about this in a, in a Wall Street Journal essay Maureen Testoni [00:12:51]: recently. The IRA was never intended to transform 340B Maureen Testoni [00:12:55]: into a rebate system. The government has refused to require Maureen Testoni [00:12:58]: 340B rebates either for the Medicare Maureen Testoni [00:13:02]: program, the drugs that are subject to the negotiation, or otherwise Maureen Testoni [00:13:06]: for 340B drugs. And drug makers absolutely Maureen Testoni [00:13:10]: have other avenues to comply with the IRA Maureen Testoni [00:13:13]: and 340B which the Centers for Maureen Testoni [00:13:17]: Medicare and Medicaid Services is saying that they are Maureen Testoni [00:13:20]: exploring as well. So it's important that Maureen Testoni [00:13:24]: we are, you know, advocating against rebates for 340B Maureen Testoni [00:13:28]: but also in the context of the Medicare Maureen Testoni [00:13:31]: negotiation scheme. David Glendinning [00:13:33]: At the top of the show you mentioned the contract David Glendinning [00:13:36]: pharmacy litigation over state laws. What is the David Glendinning [00:13:40]: latest status on those? Maureen Testoni [00:13:42]: So far we have seen a number of lawsuits from Maureen Testoni [00:13:45]: manufacturers and from their association Maureen Testoni [00:13:48]: pharmacy. And a lot of those are we're arguing Maureen Testoni [00:13:52]: that, you know, the states just do not have the authority to make Maureen Testoni [00:13:56]: any rules around 340 because 340B is a federal law. And so Maureen Testoni [00:13:59]: far they have lost those. So that has been Maureen Testoni [00:14:03]: great. However, there are some manufacturers are making Maureen Testoni [00:14:06]: new arguments around very technical Maureen Testoni [00:14:10]: issues about whether the providers retain Maureen Testoni [00:14:13]: title when the drugs are transferred to the contract pharmacy and some Maureen Testoni [00:14:17]: other issues. We are very involved in these cases. Maureen Testoni [00:14:21]: Cases. We do amicus briefs for all of these lawsuits along Maureen Testoni [00:14:24]: with a couple of others of the hospital associations and Maureen Testoni [00:14:28]: State associations. But we are also working Maureen Testoni [00:14:31]: closely with some of the attorneys that are working on some of Maureen Testoni [00:14:35]: these cases to assist with Maureen Testoni [00:14:39]: the more technical analysis about this. Whether there is Maureen Testoni [00:14:43]: any merit to some of these arguments Maureen Testoni [00:14:47]: that the manufacturers are making, I do not believe there is. But Maureen Testoni [00:14:50]: that is the case that we are really building up right now and that I Maureen Testoni [00:14:54]: expect to be the big issue in the coming year. David Glendinning [00:14:57]: You also said there's a new 340B report out, David Glendinning [00:15:00]: and our regular listeners will know that is coming from David Glendinning [00:15:04]: Minnesota, the land of 10,000 lakes. What does David Glendinning [00:15:07]: that report say? Maureen Testoni [00:15:10]: So this Minnesota report, Maureen Testoni [00:15:15]: it comes out of legislation that was Maureen Testoni [00:15:19]: passed in 2023 that Maureen Testoni [00:15:22]: requires covered any Maureen Testoni [00:15:25]: to submit certain information Maureen Testoni [00:15:29]: to the state. And one of the things that they Maureen Testoni [00:15:33]: required is that covered entities report the Maureen Testoni [00:15:37]: prices, you know, they're spending on 340B drugs Maureen Testoni [00:15:40]: and then how much they received from insurers, you know, Maureen Testoni [00:15:44]: in payment for those drugs. And that number, the number that they Maureen Testoni [00:15:48]: released was 630 million. Maureen Testoni [00:15:52]: Now, that is a calculation that we are Maureen Testoni [00:15:55]: really take issue with because it really overstates Maureen Testoni [00:15:59]: the value of 340B. 630 million is not the value Maureen Testoni [00:16:03]: of 340B. For the hospitals in Minnesota, Maureen Testoni [00:16:07]: the value is going to be lower than that. And that's because all that Maureen Testoni [00:16:11]: 340B does is it gives a discount on the Maureen Testoni [00:16:14]: drug. But hospitals that aren't in 340B don't Maureen Testoni [00:16:18]: buy the drug at the sticker price. It's called wholesale acquisition cost, Maureen Testoni [00:16:22]: which is like the car sticker price. Nobody buys it at that. And so if Maureen Testoni [00:16:25]: they weren't in 340B, they would still be getting discounts on drugs by Maureen Testoni [00:16:29]: purchasing through their group purchasing organization. So the Maureen Testoni [00:16:33]: 630 millions is a number that may apply. Maureen Testoni [00:16:37]: If everybody was purchasing their drugs at WAC and the Maureen Testoni [00:16:41]: only people that got a discount was 340B. Maureen Testoni [00:16:44]: So what you really want to do, if you were trying to see what the Maureen Testoni [00:16:47]: benefit of 340B is, is you would compare the GPO Maureen Testoni [00:16:51]: prices that hospitals have against what they're paying for 340B. So if Maureen Testoni [00:16:55]: the 340B price is 80, the GPO price is Maureen Testoni [00:16:58]: 100, and the sticker price, the WACC price is Maureen Testoni [00:17:01]: 200, then the real difference isn't going to be between Maureen Testoni [00:17:05]: that $80 and the 200. It's going to be between the $80 Maureen Testoni [00:17:09]: for 340B and the 100 for the GPO. But even looking at Maureen Testoni [00:17:13]: that 630 number, it's important to understand Maureen Testoni [00:17:17]: what that number means in terms of how much is spent on Maureen Testoni [00:17:21]: patient care by Minnesota hospitals overall? And that Maureen Testoni [00:17:24]: is $15 billion on patient care Maureen Testoni [00:17:28]: last year. And about $770 million Maureen Testoni [00:17:32]: was spent on uncompensated, unreimbursed care. So Maureen Testoni [00:17:36]: that is care where the hospital received no Maureen Testoni [00:17:40]: compensation. You know, people that just did not have insurance or Maureen Testoni [00:17:44]: care where they received, you know, less than their Maureen Testoni [00:17:47]: costs, such as, you know, Medicaid, which Maureen Testoni [00:17:50]: notoriously pays much less than the cost. And then if you Maureen Testoni [00:17:54]: were to add to that number the underpayment that hospitals Maureen Testoni [00:17:58]: receive from Medicare, I personally believe that number would Maureen Testoni [00:18:01]: be closer to a billion dollars. And so without Maureen Testoni [00:18:05]: 340B, it'd be very difficult for hospitals maintain that Maureen Testoni [00:18:08]: level of. David Glendinning [00:18:09]: Care if it's the end of the year. We here at 340B Health David Glendinning [00:18:13]: are preparing for the upcoming 340B Coalition Winter Conference. David Glendinning [00:18:17]: What are you most looking forward to for that meeting? Maureen Testoni [00:18:19]: I really love our conferences. It's just such a Great so Maureen Testoni [00:18:23]: many 340B minds in one place is just is Maureen Testoni [00:18:27]: really fun for me. And you know, this year our conference will be in San Maureen Testoni [00:18:30]: Diego. It'll be in February 24th to the 26th. Maureen Testoni [00:18:34]: I really encourage everybody who is really interested in Maureen Testoni [00:18:37]: 340B to attend. We do a lot of Maureen Testoni [00:18:41]: sessions on compliance issues, including the Maureen Testoni [00:18:45]: inflation Reduction act, the Medicare negotiation policy that I Maureen Testoni [00:18:49]: talked about earlier Sessions on optimizing 340B on how Maureen Testoni [00:18:52]: to stay compliant. On 340B, we will have sessions to Maureen Testoni [00:18:56]: sort of what to expect in Washington with the new administration Maureen Testoni [00:19:00]: and the new Congress. And our featured speaker will be a Maureen Testoni [00:19:03]: Harvard professor that's going to be discussing the future of Maureen Testoni [00:19:07]: healthcare economics. So it's a great way to network with other Maureen Testoni [00:19:10]: 340B people. It's a great way to learn about, Maureen Testoni [00:19:14]: learn new strategies that your peers may be using around Maureen Testoni [00:19:18]: 340B. You know, sharing best practices, learning new ideas, Maureen Testoni [00:19:22]: talking about 340B advocacy. Early Bird registration Maureen Testoni [00:19:25]: is going on right now and it's going to end December 20th. Maureen Testoni [00:19:29]: So I really encourage people to sign up before then so you can Maureen Testoni [00:19:33]: secure your discounted rate. David Glendinning [00:19:34]: And we will be sure to put that link and a few other links of David Glendinning [00:19:37]: interest in the show notes so our listeners don't need to venture far to find David Glendinning [00:19:41]: them. Maureen, thank you for taking the time during the David Glendinning [00:19:44]: pre holiday rush to be with us today. We all appreciate it. Maureen Testoni [00:19:48]: Well, thank you so much for having me. I really appreciate it. Dave. David Glendinning [00:19:50]: We thank Maureen Testoni again for being with us today and David Glendinning [00:19:54]: all year long. And we thank you, our loyal listeners David Glendinning [00:19:58]: for joining us during this season of 340B Insight. This David Glendinning [00:20:02]: is our last episode of 2024 and we will be taking a David Glendinning [00:20:05]: short break while we prepare for another full season of episodes David Glendinning [00:20:09]: in 2025. Please keep those ideas coming David Glendinning [00:20:13]: for episodes and guests. You can always email us at David Glendinning [00:20:17]: podcast340bhealth.org have David Glendinning [00:20:20]: a joyous, peaceful holiday season and a happy, healthy David Glendinning [00:20:24]: new Year. We will be back in January. In the meantime, as David Glendinning [00:20:27]: always, thanks for listening and be well. Outro [00:20:34]: Thanks for listening to 340B Insight. Subscribe and rate Outro [00:20:38]: us on Apple Podcasts, Google Play, Spotify, or wherever Outro [00:20:42]: you listen to podcasts. For more information, visit our Outro [00:20:46]: website@340bpodcast.org you can also Outro [00:20:49]: follow us on Twitter behealth and submit a question or Outro [00:20:53]: idea to the show by emailing us at Outro [00:20:56]: podcast@340bhealth.org.