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Consider the following scenario: A recent change in electronic health record billing at one of your outpatient clinics has led to accumulation errors in your 340B split-billing software, resulting in overpurchasing of 340B drugs. Although hypothetical, this scenario illustrates just one of many inventory-related situations that can occur during day-to-day 340B program operations. Let’s examine how to address the resulting discrepancies in your virtual inventory and explore potential next steps for resolution.
Scenario
Your 340B auditing team identified accumulation errors caused by a recent electronic health record billing change at an infectious disease (ID) clinic, which led to overaccumulation in the split-billing software and overpurchasing of 340B drugs. The issue was resolved on September 10, 2025, which included a one-time correction to the accumulations.
Virtual Inventory Report
Due to the accumulation adjustment, the 340B virtual inventory report now indicates 15.7 overpurchases for this NDC. At this stage, it’s understandable to have more questions than answers:
- Which 340B purchases are considered affected by the adjustment, and when did those purchases occur?
- What other drugs are affected by the billing issue?
- Are there additional 340B accumulations available in a different virtual inventory under the same 340B ID that could help offset the discrepancy?
What Next Steps Would You Take?
To resolve this issue, you will need to consider multiple factors and potentially take several steps. Resolution may ultimately be achieved internally, through manufacturer repayments, and/or in collaboration with your wholesaler.
For organizations facing similar challenges, a structured approach can help your team detect issues early and resolve them with confidence. Our comprehensive guide outlines a four-step action plan to achieve this:
- Identifying noncompliance through various audits
- Developing a corrective action plan
- Working with manufacturers and/or wholesalers for resolution
- Achieving successful closure
By following this action plan, healthcare organizations can better navigate complex 340B compliance issues and ensure accurate management of their virtual inventory. Download your guide to resolving noncompliance and achieving successful closure.
To learn more and schedule a meeting with an expert, visit apexus.com/CRS or email CoveredEntityRefunds@Apexus.com.
The Covered Entity Refund Service is a separate Apexus offering that is not a part of the 340B Prime Vendor Program or otherwise associated with the Prime Vendor Agreement between HRSA and Apexus.
