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KMAP BULLETIN: HRSA Medicaid Exclusions

Date: 12/02/22

KMAP GENERAL BULLETIN 22292 (PDF)

Effective with dates of service on and after January 1, 2023 and enforced with the Health Resources and Services Administration (HRSA) Medicaid Exclusion File (MEF) starting January 1, 2023, the following process for identification of Medicaid pharmacy and medical claims (Fee-for-Service and Managed Care Organization) for drug rebate invoice exclusion will be followed.

On a quarterly basis, Kansas Drug Rebate uses the MEF to determine the final list of Kansas Medical Assistance program (KMAP) billing providers to be excluded from drug rebate invoicing. The MEF is available from the HRSA Office of Pharmacy Affairs (OPAIS) 340B site here.

Approximately ten (10) days before the start of the new quarter, the Kansas Drug Rebate team will download the MEF to identify covered entities (CEs) that choose to carve-in Kansas Medicaid (as allowed in Kansas Medicaid Policy) for service dates in the new quarter. The file will be reviewed to determine if a KMAP Identifier ID on the MEF meets Kansas policy, to exclude from drug rebate invoicing.

The current MEF on the OPAIS 340B site lists the following column headers. See the site for column header definitions. 

 
Program CodeEntity Subdivision Name
340 IDStreet Address
CE IDCity
Medicaid NumberSt
StateZip
NPI NumberStart Date
Entity NameTermination Date

Only 340B ID rows that meet ALL the following will be considered for drug rebate invoice exclusion:
     ‘State’ column must be ‘KS’.
    ‘Medicaid Number’ must be a valid, active 14-digit KMAP ID AND have an ‘Enrollment Type’ of ‘Facility’ OR ‘Group’.
     ‘NPI’ must be a valid number that maps to a 14-digit Kansas Medicaid ID. 

Kansas Drug Rebate recognizes that a single 340B ID row may have multiple KMAP IDs, and National Provider Identifiers (NPIs) listed.

Kansas Medicaid will use the claim billing NPI to crosswalk to an associated KMAP ID. The KMAP ID is used to exclude claims from rebate invoicing.

This high-level claim identification exclusion process relies on the following assumption:
     The covered entity has followed state, federal, and HRSA guidelines for enrollment and registration of their providers and sites where 340B drugs are being utilized. 

Note: If there is an NPI and associated KMAP ID that are not on the MEF and a drug rebate manufacturer dispute results alleging duplicate discount, the state will defer the manufacturer to the CEs for resolution.

Note: The effective date of the policy is January 1, 2023. The implementation of State policy by the KanCare managed care organizations (MCOs) may vary from the date noted in the Kansas Medical Assistance Program (KMAP) bulletins. The KanCare Open Claims Resolution Log on the KMAP Bulletins page documents the MCO system status for policy implementation and any associated reprocessing completion dates once the policy is implemented.