What 340B consulting work actually looks like.

Situation. A mid-size disproportionate share hospital with 58 contract pharmacy locations had run its 340B program for nine years without an external test. A new pharmacy director inherited it and could not answer basic questions about how the patient definition was being applied.

What we did. A five-week mock audit across all 25 test areas, working with real claims across every service line, the full OPAIS record and every contract pharmacy agreement.

What we found. Ineligible referral claims across three service lines, driven by referral documentation that did not link the encounter to the entity. A Medicaid Exclusion File status set at registration and never revisited after billing practice changed in two states. Fourteen contract pharmacy agreements more than four years old, three referencing a corporate entity that no longer existed.

Outcome. Remediation completed before annual recertification. The referral documentation workflow was rebuilt, which also increased legitimate capture. Oversight documentation now exists per location.

Situation. A health system oncology service line was evaluating a move of infusion services from a hospital outpatient department to a new freestanding location. The pro forma showed a clear operational saving and had reached the point of board consideration.

What we found. The model addressed facility cost, staffing and reimbursement, and did not address 340B eligibility at all. On a service line where drug cost dominated, the eligibility change at the proposed site materially outweighed the facility savings.

What we did. Rebuilt the model with chair utilization, payer mix, site-neutral reimbursement and 340B eligibility as one integrated view, then modeled three alternative scenarios including expansion at the existing HOPD.

Outcome. The move was not pursued in its original form. Capacity was expanded at the existing site instead, with a scheduling redesign that addressed the underlying constraint.