Expert Tip from AAFCPAs

Monitoring and maintaining an active patient listing (APL) for all patients whose prescriptions qualify as eligible under the 340B program is imperative. This APL should be updated daily and maintained through the electronic medical record system. The entity’s 340B policy should specify the time period during which a patient is deemed active based on their last visit with a covered service provider and scope of service.

The APL should be reviewed in consideration of changes in providers, covered services, and patient termination. For example, if a provider leaves the 340B entity, all affected patients with current monthly prescriptions should be reassessed for eligibility depending on transfer of care to a new provider. Managing the APL can be arduous and time consuming if technology is not leveraged to manage maintenance and to highlight potential exceptions. Speaking with a reputable 340B service provider can help you streamline this process and minimize risk.