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In the world of 340B, one thing is certain: change is constant. Every week seems to bring a new manufacturer restriction, operational challenge, compliance concern, or process update that impacts how covered entities manage their programs. Trying to stay current while also optimizing savings and maintaining compliance can feel overwhelming even for experienced teams.
As 340B Program Managers, we have learned many lessons over the years. One of the biggest lessons is simple: don’t be afraid to ask. Some of the best outcomes we have seen for clients did not come from accepting the status quo — they came from asking questions, challenging processes, and advocating for better solutions.
Too often, organizations assume the answer will be “no,” so they never ask in the first place. In the 340B space, asking the right question can lead to operational improvements, financial recovery, and stronger partnerships.
Ask About Designation Errors
One example is requesting an exception for an early single contract pharmacy designation change. Manufacturers occasionally classify pharmacies or claims incorrectly, which can impact replenishment eligibility or access to products. While these situations can be frustrating, we have seen success simply by escalating concerns and asking for a review. Sometimes additional context or clarification is all that is needed to resolve the issue.
Ask About Negative Balances
Another area where asking matters is addressing erroneous negative submission balances on the upload platforms. Whether due to a system error, timing issue, or operational breakdown, negative balances can create significant financial impact and loss of patient access for covered entities. Many organizations assume they are helpless, but manufacturers will often work collaboratively to forgive balances or help correct the issue when approached professionally and with supporting documentation. The key is being willing to initiate the conversation.
Ask About Your Purchasing Rates
Wholesaler relationships also present opportunities for improvement. Many covered entities are so focused on day-to-day operations that they never stop to evaluate their purchasing rates. Asking your wholesaler to clearly define the rate at which products are being purchased — and whether there are better rates or contract options available — can uncover opportunities for savings that otherwise would have been missed.
Ask About Substitute NDCs
Similarly, asking about substitute NDCs can help maintain program continuity during shortages, access issues, or restrictive purchasing situations. There are times when an alternate NDC can support replenishment needs or provide a more cost-effective purchasing option. These solutions are not always proactively presented, which is why asking the question is important.
Ask Your TPA to Explain Their Process
The same mindset applies to technology and administrative partners. Asking your TPA to define their current process can provide valuable transparency into how claims are being qualified, accumulations are functioning, and where potential gaps may exist. In many cases, clients discover opportunities for optimization simply because they took the time to better understand the TPA processing details.
Ask Your TPA to Review Plan Edits
In addition, asking your TPA to review current plan edits can help identify configurations that may no longer align with program goals or operational realities. Plan edits established during implementation may unintentionally limit capture opportunities today. Periodic review and open discussion can help ensure your program remains aligned with both compliance requirements and optimization strategies.
Ask Your Pharmacy Partner About Plan Design
Pharmacy relationships are another area where asking questions can create meaningful change. Asking your pharmacy partner to negotiate or revisit plan design can sometimes improve claim capture, reduce operational burdens, or better align incentives among all parties involved. Strong partnerships are built on communication, and collaborative discussions often lead to solutions that benefit everyone.
Don’t Be Afraid to Continue Asking Questions
The reality is that no 340B program operates perfectly all the time. Challenges will continue to emerge as the landscape evolves. However, organizations that remain curious, engaged, creative and willing to ask questions are often the ones that uncover the greatest opportunities for improvement.
In 340B, asking questions is not a sign of inexperience — it is a sign of strong program management. Whether you are speaking with manufacturers, wholesalers, TPAs, pharmacies, or internal stakeholders, never underestimate the value of asking for clarification, asking for review, or asking for a different solution.
Sometimes the answer may still be no. But often, asking the question is what leads to the breakthrough your program needs.
Samantha Mantuano is Senior Director of Program Management Operations at Pillr Health. She can be reached at smantuano@pillrhealth.com.
