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Avoid These Six Common Errors When Reporting 340B-Eligible Prescriptions Through 340B ESP

Until Congress and/or the courts give HRSA the legal authority it should have to enforce the 340B program’s regulations established by Congress in 1992, eligible entities seeking to maximize 340B savings and revenue will continue being, for all practical purposes, strongarmed into reporting a significant percentage of their eligible prescriptions through the 340B ESP website. 

Below are six of the most common errors made by entities in reporting 340B-eligible prescriptions — and our advice for avoiding them. (To read our complete blog post on the topic, Click Here.)

1. Uploading Excessive 340B Data 

Never upload more data than is absolutely necessary, and required, by 340B ESP. We submit the NDCs only from the manufacturers imposing restrictions on 340B pricing contingent on data reporting. 

2. Trusting 340B ESP to Restore Prices On Its Promised Scheduling

Don’t ever assume that 340B prices are restored in your contract pharmacies’ 340B wholesaler accounts by the 10-day post-submission mark (the time frame 340B ESP says to allow). NOTE: It’s critical that you check all NDCs, in all of your contract pharmacies’ 340B accounts, before instructing your TPAs to restart processing on any restricted NDCs. 

3. Trusting 340B ESP Price Restoration, Period

When dealing with 340B ESP, never assume that any 340B price restoration you have will actually be honored. If any manufacturer working with 340B ESP decides, unilaterally, that the purchases made for any of your contract pharmacies are more than the dispenses, they’ll refuse to pay the wholesaler’s chargeback. 

4. Assuming submitted eligible dispenses result in 340B price access

Eligible 340B dispenses often do not occur in full-package-size increments. It may take months, and multiple claims, to equal a full reorderable package size. But some manufacturers will not allow 340B purchases past 45 or 60 days from dispense. Which means covered entities will likely never be able to get many of the 340B prices they are entitled to. 

5. Counting-On 340B ESP-Compatibility In Your TPAs’ Reports

When you submit your own reporting to 340B ESP, you can’t simply pull reports from your TPAs and upload them. Not without making significant modifications. Your uploads must be submitted in a highly-specified format, and every upload is fraught with potential pitfalls that can cause failures.  

6. Counting-On Support From 340B ESP

At the very top of the 340B ESP home page, you’ll find an email address — Don’t waste your time. In our experience, nobody working with 340B ESP — or the manufacturers — will help you when you don’t receive the 340B prices to which you’re entitled, even if months have passed since your first data submission. 

The good news about 340B ESP, for covered entities

Despite the well-founded outrage over 340B ESP and manufacturer restrictions, ProxsysRx continues to generate significant savings and revenues for the health systems we serve. Altogether, our efforts have generated tens of millions in 340B savings and revenue for the hospitals we serve.

ProxsysRx is here to help, if you have questions. 

There are so many ways to optimize your 340B drug program savings and benefits, while minimizing the likelihood of noncompliance. For more information, contact Howard Hall.

C: 205.588.0946 |

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