Over the last 72 hours, the Trump Administration has made a flurry of announcements that directly endanger the lives of millions of Americans and our neighbors around the world. We are particularly alarmed by the directive to pause the disbursement of all federal grants and loans, and Executive Orders curtailing protections around diversity and LGBTQIA+ rights. These policies and directives directly hurt our safety net clinic partners and the patients they serve.
What does this mean for Covered Entities?
- 340B Grant Eligibility. All covered entities require ongoing eligibility to participate in the 340B drug program. Without a federal grant (Ryan White, Section 318 grant (STD), or Section 330 grant (FQHC)), these entities will be unable to participate in the 340B program.
- Federal Grant Funding. Many federal grantees rely on federal funding sources to cover portions of their day-to-day operational costs of running a clinic. A pause on these federal funds directly impacts their ability to “keep the lights on” and operate their clinics. The impact of this will be felt immediately and the health of millions of Americans impacted as a result.
- Existing 340B Grant Renewal Process. The temporary pause on federal grant payments will also impact the renewal process for covered entities. Current guidance is that delays in recertification should not hinder program eligibility. Regardless, we recommend all covered entities do a careful review of all their locations and grant renewal timelines.
- New 340B Grant Process. We believe this temporary freeze will also impact new grant issuances. We advise planning for delays in obtaining new 340B grants.
- Manage External Stakeholders. We recommend Covered Entities with in-house pharmacies be in conversation with all external stakeholders, starting with their drug wholesalers. Drug wholesalers will play an integral role in determining how to manage through the potential disruption of delays in 340B grant renewals. We are optimistic and doing everything we can to ensure that wholesalers do the right thing here by continuing to extend 340B drug purchasing and allow pharmacies to continue operating.
What does this mean for Alchemy?
- Stay Focused on Our Mission: Our commitment is to serve covered entity partners, by being a true partner to our clients, through thick and thin. It is the reason our organization exists. This may involve going above and beyond to support our partners in this time of crisis.
- Continue Executing. The most important thing we can do as a company is to continue focusing on client & project execution. In many ways, this accelerates the urgency of our 340B programs for our clients. Every dollar coming into a covered entity via an in-house pharmacy program can help offset a dollar displaced by the freeze on federal grant payments.
In this challenging time, Alchemy stands shoulder-to-shoulder with all of our Covered Entity partners. As LGBTQIA+ rights and the public health safety net come under attack, our work - and our resolve - are more important than ever.
List of Relevant Executive Orders and Policy Actions:
- OMB Memo freezing all federal grants and loans: “Federal agencies must temporarily pause all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders, including, but not limited to, financial assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal.”
- Key HIV resources being pulled down / removed from .gov websites
- Source: GLAAD:
- Pages removed include WhiteHouse.gov’s equity report (no longer accessible), a fact sheet with information on expanding access to HIV prevention and treatment (no longer accessible), and information about LGBTQ Pride Month (no longer accessible). Agency page removals include Department of State’s LGBTQ rights (no longer accessible), and Department of Labor’s LGBTQ workers page (no longer accessible).
- Source: GLAAD:
- NIH cancels scientific meetings (where future research grant funding decisions are made), at new administration’s directive
- Trump pauses funding for PEPFAR -- prevented 26 million AIDS deaths (unrelated to 340B, but with significant impacts to HIV care globally)
- Trump curtails protections around diversity, LGBTQ rights
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