TIP: If your entity engages a firm to independently audit your 340B Program, follow through on the auditor’s recommendations in a timely manner.
If you’re working with an outside auditor to examine your entity’s 340B activities annually, they should not be turning over the same findings year after year. Independent auditors are there to help your organization identify risks. It’s up to your team to leverage this expertise to resolve both compliance and administrative deficiencies. Diversion and duplicate discounts are top priorities for HRSA, but they also examine the 340B OPAIS, contract pharmacy service agreements, and wholesaler invoices.
This sounds like a no-brainer, but during my 20-plus years as a 340B compliance expert, I’ve seen HRSA auditors cite entities on findings that could have been resolved prior to the audit—using insights gleaned from the entity’s previously conducted external and internal reviews.
Cheryl Hetland, VP, 340B Program Management at Avita Care Solutions, can be reached at email@example.com.