May a Hemophilia Treatment Center (HTC) that is part of a hospital participate in a GPO for outpatient drugs?

The answer depends on how the HTC is registered with respect to the hospital.

• If the HTC is within the four walls of a parent hospital subject to the GPO prohibition and not separately registered for the 340B Program with a 340B ID beginning with “HM”, the HTC may not use an outpatient GPO.
• If the HTC is registered as an off-site outpatient clinic of a hospital subject to the GPO prohibition, the HTC may not use an outpatient GPO.
• If the HTC is an off-site outpatient facility of a hospital subject to the GPO prohibition, but is not registered for the 340B Program (as a child site of the hospital) and meets all of the following, it may use a GPO for covered outpatient drugs:
  1. Is located at a different physical address than the parent;
  2. Is not registered on the OPA 340B database as participating in the 340B Program;
  3. Purchases drugs through a separate pharmacy wholesaler account than the 340B participating parent;
  4. The hospital maintains records demonstrating that any covered outpatient drugs purchased through the GPO at the HTC are not utilized or otherwise transferred to the parent hospital or any outpatient facilities registered on the OPA 340B database.
• If the HTC is otherwise an eligible entity and registered as such (340B identification number beginning with “HM”), then it is not subject to the GPO prohibition with respect to its own patients.
• In no circumstances may the HTC’s permitted use of a GPO be used to circumvent the GPO prohibition for a hospital and its outpatient clinics subject to the GPO prohibition.