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Latest "Pharmacy Services" Posts

Succeeding with HRSA 340B Audits: 4 Things you can do to Ensure Success

The HRSA audit process for 340B seems to be a mysterious process, where a lot of fear and anxiety reside. Having led Covered Entities through the HRSA 340B audit process, I thought I would give a little insight from these experiences as too what might help you to be successful.


1. Assess your Program, Create a Work Plan

You need to gather some baseline information about your program, prior to creating a plan to keep compliant with 340B. Many will point to free resources, such as Apexus tools and resources as a guide. Others rely heavily on software vendors. While these are tremendous resources, there is not a “one-size fits all” solution and the material takes a significant amount of time to navigate.

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Posted by Tim Kerr on May 27th, 2016 in Pharmacy Services

340B Mega Guidance: A Tough Pill to Swallow for Some

HHS published its much anticipated Omnibus guidance (“Mega Reg”) on August 28, 2015. The full document, which includes 90 pages of information is located here.

Upon reading of this document, discussion with colleagues in the 340B space, and reading of multiple blog posts, I thought I would take a stab at summarizing some of what is included in the guidance.

Perhaps the biggest change, which is always good water cooler discussion in the 340B community, is further clarification, or in this writer’s opinion “narrowing” of the “Definition of a Patient”. The existing definition of a patient is found here on the OPA website. Sparing you the details of the existing definition, let’s jump right into what the proposed new definition of a patient is, and how it might change your program.

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Posted by Aaron Miller on September 15th, 2015 in Healthcare Improvement, Pharmacy Services