3 Tips for Navigating the Current 340B Environment


Many people have been losing sleep thinking about how they should move forward in the current 340B environment. Over the last 18 months, it has felt like an external force is around every corner, pushing or pulling covered entities into new areas of discomfort.

During these turbulent times, it can help to find partners who have experience as covered entities and have weathered storms historically. As a wholly owned subsidiary of a covered entity, Hudson Headwaters 340B helps covered entities navigate the complexity of the current 340B environment and assists in developing strategies and technology solutions to minimize the discomfort and uncertainty of today.

Below are three things we suggest to improve the value and efficiency of your organization’s 340B program.

1. Automate Your ESP Data Submission

Hudson Headwaters 340B knows first-hand the challenges of reporting data to Second Site ESP. We have worked with ESP over the last several months, building out the API integration to submit data at the request of our clients. This process enables the covered entity to submit data to ESP by manufacturer and contract pharmacy location. We anticipate further portal enhancements with this process in the months to come. 

2. Ensure Accuracy with Wholesaler Price Verification

Earlier this year, Hudson Headwaters 340B conducted a poll and found that 21% of respondents did not review their wholesaler invoices to ensure pricing accuracy.

We then conducted a follow-up poll to determine how much time covered entities spend reviewing wholesaler invoices for accuracy. We found that 67% spend more than four hours per month reviewing invoices for accurate 340B prices. Additionally, 17% spend less than two hours per month, with another 17% spending no time per month reviewing invoices.

As a standard service offering to our clients, we perform this function as part of our TPA service and have recovered over $1 million in the last twelve months for our clients. Reviewing this information is critical and can lead to additional savings that would otherwise go unnoticed.

3. Use Referral Capture to Recover Savings

One of the easiest and most effective ways to recover savings for your covered entity is to work with your TPA to capture referrals.

One of the key factors to consider when capturing referrals is ensuring that those doing the work on your behalf adhere to your organization’s policies and procedures. This is especially important if and when you must produce the documentation for an audit.

Another thing to consider is the cost-benefit of outsourcing the service versus performing the service in-house. With 340B savings diminishing on other fronts due to manufacturer restrictions, finding the most cost-effective approach to managing referrals is key.

Looking Ahead to the Second Half of 2023

The remaining half of 2023 will likely be filled with uncertainty. But as history tells us, those with the steadiest hands can endure the most turbulent of storms and uncertain waters. In order to have a steady hand, you have to understand how the wind works.

Attending webinars and conferences can help you understand the current 340B environment and give you the opportunity to share your knowledge with others. It’s why we include so many guest speakers, roundtable discussions, and networking in our own annual Client Forum.

Together, we can help each other weather the storm and come out on the other side with the healthcare safety net stronger than ever.

We hope these tips will help you to make the most of your 340B program. If you have any questions, please feel free to reach out directly to ahomkey@hudson340b.com or visit us at Hudson340B.com.

Nick Rebmann is CEO at Hudson Headwaters 340B.

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