SPONSORED CONTENT
Introduction: Navigating Political Headwinds
As the 2025 political season heats up, federally qualified health centers (FQHCs), hospitals, STD clinics, Ryan White grantees, and other covered entities must brace for another round of uncertainty. With renewed debates around entitlement spending, federal grant allocations, and healthcare oversight, programs like 340B are once again in the crosshairs. For covered entities relying on 340B savings to deliver vital services, political volatility is not just noise, it’s a threat to sustainability.
To weather this storm, it’s no longer enough to comply with 340B regulations. Entities must proactively optimize their programs, uncover untapped savings, build financial resilience, and uncover additional sources of eligibility when possible.
Maximizing Savings in an Uncertain Environment
The first line of defense is ensuring your program is capturing every eligible prescription and patient encounter. Far too many covered entities leave money on the table due to:
- Incomplete data integration between EHR, pharmacy, and third-party administrator (TPA) platforms;
- Missed eligible encounters due to improper provider credentialing;
- Insufficient contract pharmacy oversight or underutilization of in-house pharmacies.
A comprehensive 340B optimization assessment can identify these blind spots and help covered entities recover hundreds of thousands of dollars in potential savings.
Key Recommendations from Recent Optimization Engagements:
- Audit Encounter Capture: Routinely compare medical billing data with 340B claims to identify unlinked encounters. Minor discrepancies in documentation or provider type can lead to disqualifications.
- Enhance Provider Rosters: Ensure that all prescribers are properly configured in your TPA platform, especially in rotating residency or telehealth models.
- Strengthen Contract Pharmacy Terms: Renegotiate terms where pharmacy partners are taking excessive revenue share. Many entities are still utilizing outdated contracts with little ROI.
- In-House Pharmacy Review: Evaluate whether opening or expanding an in-house pharmacy could offer greater long-term control, especially as manufacturers continue to restrict contract pharmacy access.
- Referral Capture Optimization: Implement procedures to improve documentation and tracking of referred care, particularly for Ryan White and STD clinic models where referral relationships are vital.
Diversify and Future-Proof Your Funding
Optimization is only half the equation. To further insulate against potential federal cuts, covered entities should explore pathways to expand their eligibility and access additional funding streams:
- Apply for Look-Alike or FQHC status if eligible, unlocking Section 330 grants and higher Medicaid PPS rates;
- Consider Ryan White Parts C or D participation, which provides direct funding and greater 340B leverage;
- Strengthen grant-writing capacity to aggressively pursue discretionary and formula-based state and federal funding.
Covered entities should also revisit their sliding fee scales, scope of project documentation, and scope verification protocols to ensure maximum alignment with Bureau of Primary Health Care (BPHC) and HRSA standards.
Leverage Data for Strategic Planning
In times of uncertainty, data isn’t just for compliance, it’s your strategic compass. Innovative ways to track metrics such as the examples below will help executive teams make informed decisions about staffing, expansion, and contingency planning. They include:
- 340B savings over time;
- Cost avoidance trends;
- Patient reach by service line;
- Pharmacy partner performance metrics; this will help executive teams make informed decisions about staffing, expansion, and contingency planning.
Be Prepared, Not Paralyzed
While it’s tempting to adopt a wait-and-see approach, the most resilient 340B programs are those that act now. By conducting a thorough 340B optimization assessment, improving operational efficiency, and diversifying funding sources, covered entities can weather political shifts without compromising care.
If you haven’t conducted a formal 340B optimization review in the past 12 months, now is the time. The cost of inaction could far outweigh the investment in a proactive assessment.
Robert Ferraro is principal and chief operating officer at Ravin Consultants. He can be reached at robert@ravinconsultants.com.
