340B Compliance Audit Improves Processes and Reduces Risk

IndustryRetail Pharmacy
ProblemA 340B contract pharmacy client requested a gap analysis to identify any issues that needed to be addressed in the management controls, processes, and procedures to ensure that their pharmacies and their associated covered entity health system complied with 340B Drug Pricing Program regulations.
PHSI SolutionA compliance audit was conducted including pre-selection of auditable claims by type, onsite interviews, review of policies and procedures, and management controls. This review enabled PHSL to recommend operational changes to their policies and procedures, along with implementing feedback mechanisms for better management controls of the end-to-end process.
ResultsAdditionally, PHSL identified Medicaid fee-for-service claims that were being captured as 340B eligible, despite the covered entity being a carve-out facility. The contract pharmacy was able to work with the covered entity and the third-party administrator to avoid duplicate discounts and a potential HRSA audit finding.