Four Steps to Employing a
Compliant 340B Program



By: Jeff Spencer

It’s not new information that 340B audits by the Health Resources and Service Administration (HRSA) are steeply increasing. In 2014, HRSA committed an additional $6 million to increase 340B program integrity and oversight. HRSA completed a total of 789 covered entity audits between 2012-2017.

Considering this, it’s critical that hospitals and health systems participating in the 340B program are not just compliant today but employ a systematic approach to continued compliance. The following recommendations can assist you in achieving this goal.

  1. Implement up-to-date policy and procedures that reflect best practices and your organization’s unique operations
  2. Develop a robust, internal auditing program. The more frequent – the better.
  3. Promote education and 340B advocacy across the covered entity including your leadership.
  4. Schedule an independent audit of your 340B program

Presently, HRSA audits are a given, but adverse findings don’t have to be. With robust policies and procedures, documentation, and an enterprise-wide commitment to compliance and education you can be successful. Download the full compliance guide to learn more!

Compliance Brief white paper

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Jeff Spencer is an experienced consultant in the pharmacy healthcare industry with special expertise in 340B drug programs, health system pharmacy strategies, employee benefit integration, data analysis, program benchmarking, and development of custom client deliverables such as executive-level reports and financial projections.