SPONSORED CONTENT
For health systems participating in the 340B Drug Pricing Program, maintaining compliance and optimizing operations are top priorities. One essential tool in achieving these goals is the development of a location crosswalk, especially important for Covered Entities (CEs) with child sites, as required by the Health Resources and Services Administration (HRSA).
What is a Location Crosswalk?
A location crosswalk is a comprehensive mapping tool that connects each eligible service location to the key data elements needed to support 340B compliance and operational integrity. At a minimum, a comprehensive location crosswalk should include:
- 340B ID
- Service line cost center
- Medicare cost report line number for the service line
- Service line address
- EMR patient registration departments aligned to that service line
By bringing these elements together, the crosswalk helps ensure that all participating sites, including child sites, are accurately documented, consistently represented across systems, and aligned with HRSA requirements.
Why is a Location Crosswalk Necessary?
- HRSA Compliance: For CEs with child sites, a location crosswalk is critical for meeting HRSA’s stringent compliance requirements. It ensures that all locations are correctly registered and reported, reducing the risk of audits and penalties.
- Operational Optimization: Beyond compliance, a location crosswalk serves as a strategic tool for optimizing 340B operations. By providing a clear view of all participating locations, health systems can better manage resources, streamline processes, and identify new potential child site.
Quick Tips for Identifying Eligible Locations
When building a location crosswalk, a few foundational checks can help determine whether a location may be eligible for inclusion in the 340B program:
- Start with reimbursable services on the Medicare cost report. Eligible locations are generally tied to cost centers or service lines that are reimbursable on the Medicare cost report and show outpatient charges.
- Focus on reimbursable line numbers. In general, reimbursable lines are those that fall between lines 50 and 118 on the Medicare cost report.
- Confirm the physical address. If a reimbursable outpatient service line is not located at the same address as the parent site, it must be registered as a child site to be eligible for 340B participation.
- Do not overlook discharge prescriptions. Discharge prescriptions may still be eligible, so those areas should be included in your location crosswalk when identifying areas of capture for the retail and contract pharmacy universe.
These checks can serve as a practical starting point, but organizations should also validate each location against HRSA registration requirements and their internal supporting documentation.
Challenges in Developing a Location Crosswalk
Creating a comprehensive location crosswalk can be challenging because data often differs across systems. Department names, service line descriptions, cost centers, addresses, and registration mappings may not align cleanly between the Medicare cost report, HRSA database, and EMR. Successful development typically requires close collaboration among IT, Finance, Revenue Cycle, and the 340B team to maintain consistency, accuracy, and appropriate maintenance over time.
Conclusion
Building a location crosswalk is a vital step for any health system looking to optimize its 340B operations while maintaining HRSA compliance. By accurately mapping all participating locations, your organization can achieve greater efficiency and enhance its ability to provide quality care to the community.
For more information on creating a location crosswalk or to explore optimization strategies for your 340B program, reach out to our team at 340Bconsulting@cencora.com.
Anaila Moreau is Managing Director, 340B Consulting & Optimization,
Accelerate Pharmacy Solutions at Cencora.
