Todd Nova: Aligning 340B Optimization with Health System Strategy

In this episode of How Health Systems Work, hosts Jim Burke and Steve Pratt are joined by Todd Nova, a nationally recognized healthcare attorney at Hall Render, to break down the 340B Drug Pricing Program and why it matters so deeply to hospitals and underserved communities. Todd shares his background in healthcare law, pharmacy, and reimbursement, offering a practical perspective on a program that sits at the intersection of policy, operations, and patient care.

The 340B program requires drug manufacturers to provide discounted outpatient drugs to eligible hospitals and safety-net providers in exchange for access to Medicare and Medicaid reimbursement. While the statute itself is brief, the program is extraordinarily complex, touching everything from cost reporting and pharmacy operations to IT systems and Medicaid policy. For many hospitals, eligibility is tied to Disproportionate Share Hospital (DSH) percentages, making 340B a key driver of strategic decisions and service line sustainability.

Todd explains that despite growing scrutiny and pressure from pharmaceutical manufacturers—particularly around contract pharmacies and transparency—the program continues to function as intended. 340B savings allow hospitals to maintain critical services such as infusion centers, behavioral health, labor and delivery, and rural access points that might otherwise close, especially in Medicaid-heavy and underserved areas.

Looking ahead, Todd emphasizes that while the 340B program will likely change, it is not going away. For health system leaders, the focus should be on responsible participation: investing in the right expertise, balancing opportunity with compliance risk, and ensuring the program supports the organization’s mission. When managed well, 340B remains one of the most important tools for sustaining care for vulnerable populations.

Chapters

00:00 Introduction to the 340B Program

01:50 Understanding the Basics of 340B

05:04 The Impact of 340B on Healthcare Systems

10:26 Challenges and Pressures Facing the 340B Program

15:03 Political Dynamics and the Future of 340B

17:31 Navigating the 340B Program Challenges

21:22 C-Suite Strategies for High-Performing Health Systems

25:36 Integrating Pharmacy into Health System Strategy

29:40 Maximizing Financial Benefits of 340B