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TIP: When a covered entity participates with 340B ESP™ to obtain 340B pricing restoration, it is critical to monitor manufacturer policies, ESP eligibility, wholesaler pricing, TPA settings, and data submission accuracy on a routine basis.
Consistent monitoring is critical to ensure uninterrupted access to 340B pricing when submitting data to 340B ESP™. Begin by reviewing manufacturer policies regularly—these can change frequently and are available through resources like the 340B ESP™ Resources page and the 340B Report. Be aware of any manufacturer-specific requirements, such as requirements to submit in-house retail pharmacy data. Keep in mind that manufacturers do not routinely notify CE’s when they are updating their pricing policy.
An eligibility file is available to download from the 340B ESP™ portal. The file is the source used for determining 340B pricing eligibility, so it is important to confirm that your contract pharmacies are appropriately listed as eligible and promptly follow up on any discrepancies. Once pricing eligibility is confirmed within 340B ESP™, track wholesaler pricing catalogs to validate pricing has been appropriately restored and identify any issues early. TPA (third-party administrator) settings should be reviewed routinely to ensure that appropriate blocks are in place and no contract pharmacies are improperly excluded from data submissions. Additionally, confirm that your submission balances in the 340B ESP™ portal accurately reflect the pharmacies you intend to include in data submissions. Validate that in-house pharmacies are listed accurately and that contract pharmacy data submissions are being applied accurately to balances.
Finally, be aware of relevant state-level laws that may impact contract pharmacy relationships and data sharing. A routine, comprehensive review of these areas helps protect your pricing and ensures compliance with evolving 340B program requirements.

Dani Stewart is 340B Program Director at Visante. She can be reached at astewart@visanteinc.com
