In this episode of How Health Systems Work, Jim Burke and Steve Pratt talk with Todd Nova, a nationally recognized attorney at Hall Render and one of the foremost legal experts on the 340B drug pricing program. Todd brings his two decades of experience advising hospitals, health systems, and safety-net providers to help unpack the complex reality of 340B — its origins, its current pressures, and how health systems can navigate it responsibly and strategically.
The conversation spans a wide range of topics, including how 340B savings impact financial sustainability, why program participation is often misunderstood, and the operational and legal risks of aggressive optimization tactics. Todd explains the practical link between Medicaid reimbursements, disproportionate share hospital (DSH) thresholds, and the survival of inpatient psychiatric and maternal health programs in underserved communities. He also lays out what hospital leadership must understand about compliance, strategy, and governance when engaging with 340B.
Whether you’re at the start of your 340B journey or already deeply involved, this episode is a valuable roadmap for aligning compliance with mission — and ensuring your organization doesn’t leave critical value untapped.