Expert Tip from Shelly Oppong interim COO at 340Best

December 7, 20230


Create and maintain a comprehensive crosswalk or log documenting your 340B registered sites, contract pharmacies, and all associated contract pharmacy agreements.

Keeping a strategic log of essential 340B data elements is crucial for preserving your 340B eligibility. Regularly update your log with any new 340B contracts, clearly specifying the applicable sites (340B IDs) for each. This practice ensures efficient confirmation of registration accuracy, especially during quarterly internal or external audits. To streamline this process, consider leveraging the OPAIS database and incorporating additional fields for enhanced tracking.

Focus on key information to ensure effective oversight:
1. Covered Entity Information:
  • 340B ID
  • Name and Address
  • Sub-Division Name

Why: Enables swift confirmation of accurate registration during audits and compliance assessments.

2. Contract Pharmacy Information:
  • Pharmacy Name and Address
  • Pharmacy ID

Why: Essential for monitoring contract pharmacy relationships and ensuring compliance with 340B program requirements.

3. Contract Information:
  • Contract Document Name and Location
  • Contract Begin and End Dates
  • Contract Approval and/or Termination Date (OPAIS)

Why: Facilitates effective contract management, ensuring timely renewals and adherence to approval timelines.

4. Contract Pharmacy Rep Information:
  • Rep Name and Contact Details

Why: Streamlines communication and oversight of contract pharmacy relationships.

By focusing on these key data points, you enhance your ability to navigate audits, manage contracts efficiently, and maintain compliance with 340B program regulations.

Shelly’s Tip was originally published in 340B Report, your indispensable source for news and information about the 340B program.

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