Expert Tip From Hudson Headwaters 340B

It is always important for covered entities to be reviewing their wholesaler invoices to ensure accurate 340B pricing is being applied. The entity should be looking to make sure that the 340B price is extended for all NDCs and that they are not being charged Wholesaler Acquisition Cost (WAC) for their 340B purchases. These pricing discrepancies can be caused by a delay in the manufacturer providing 340B contracts to the wholesaler, an administrative error by the wholesaler, or a misinterpretation of data resulting from ESP data submission complexities.

When reviewing wholesaler invoices, covered entities should note incorrect pricing and request a credit and rebill from the wholesaler. An inquiry should be sent to the wholesaler with all original invoice and item-specific information, the estimated 340B amount that should have been charged, and a calculation of the difference.

The volume of pricing discrepancies seen by Hudson Headwaters 340B’s wholesaler pricing verification team is at an all-time high. There are likely many covered entities losing 340B savings through inaccurate pricing being charged erroneously by the wholesalers.