340B Drug Discount Program & Contract Pharmacy Management

Why is 340B Compliance Important?

 

Covered Entities can face sanctions for non-compliance, including being removed from the 340B program and/or repayment to manufacturers for the time period for which the violation occurred. 

We work with clients to:

 

  • Identify and facilitate strategic partnerships between programs and providers

  • Develop a clear way to validate patient eligibility

  • Review a report of health care professionals’ NPIs to determine only professionals meeting all aspects outlined in the patient definition write for 340B drugs

  • Regularly verify referrals for care provided outside the entity

  • Review billing practices for Medicaid and Medicaid managed care to ensure consistency with state policy and the entity’s 340B database information

  • Maintain updated Policies & Procedures on all aspects of 340B purchasing and operations

  • Ensure all information in the 340B database is current

  • Implement and maintain 340B Compliance

Entities are Responsible for Ensuring:

  1. Only eligible patients receive 340B drugs

  2. A Medicaid rebate is not paid on a 340B purchased drug

  3. All entity eligibility requirements are met