TIP: Prepare for additional HRSA scrutiny on 340B clean sites with these 3 best practices.
The CPS 340B solutions team routinely participates in HRSA 340B program audits as part of our ongoing partnership with covered entities across the nation. Recently, we’ve seen HRSA auditors focus additional scrutiny on 340B clean sites, which leads us to provide this expert tip. For those who may be unfamiliar, a 340B clean site refers to a 340B-eligible location which uses a physical 340B-only inventory.
For 340B clean sites, the following best practices are recommended to ensure 340B drug diversion does not occur:
- Perform periodic inventory counts of 340B drugs located and/or used in clean sites.
- Compare 340B clean site purchases with dispensations to ensure no variances exist.
- Maintain records to document when 340B drugs for the clean site are either destroyed or wasted.
In addition, we recommend your covered entity’s policies and procedures are updated accordingly based on any specific practices for clean sites.
Dennis Killian is director of 340B Solutions at CPS. He can be reached at Dennis.Killian@cps.com