Reduce compliance issues and optimize your program by avoiding these common errors.
The requirements and processes associated with 340B ESP™ data submission and price restoration
monitoring are complex and ever-changing. If you are a Covered Entity (CE), then you realize just how
challenging and time-consuming it can be to keep up with managing your 340B program.
At Visante, our 340B ACE-certified consultants are experts on 340B ESP™ processes. In fact, we have
worked with dozens of CEs to help them regain lost revenue quickly and efficiently. These are the most
common mistakes we see when it comes to 340B compliance – and how you can avoid them.
1. Unnecessary Wholesale Acquisition Cost (WAC) expenditures.
Many CEs can decrease unneeded WAC expenditures by focusing on the resolution of these five
• Incorrect BUPP package size set up within the accumulator(s).
• Increase in Medicaid patients for carve-out CEs.
• Data feed issues (for example, missing or blocked locations).
• Lack of claims information to match purchase data in the accumulator.
• Improper drug mapping in the accumulator.
2. Not taking screenshots of wholesaler orders.
In today’s challenging supply chain environment, if a drug MUST be ordered on GPO in order to access a
product that will otherwise create an inventory gap, it is critical that you take screenshots to demonstrate
the lack of product availability on 340B and/or WAC. Without these detailed records, your 340B program
is out of compliance and may face penalties.
3. Not submitting data twice per month.
The 340B ESP™ platform requires CEs to submit data twice per month, or face risks for losses and lag
time in 340B price restoration. CEs should pull data from all Third-Party Administrators (TPAs) and
validate it against expected claims. It is also important to monitor 340B ESP™ regularly to verify which
pharmacy locations and manufacturers are still not showing restored pricing.
4. Diversion or duplicate discount issues due to technology settings.
These issues are often caused by minor technology configuration settings or EMR settings/defaults that
can lead to manufacturer repayment and HRSA audit findings. Visante can help review your existing
technology configuration settings and EMR feeds to ensure maximum compliance, while also optimizing
5. Not reviewing carve-out/ineligible claims data.
For CEs with a contract pharmacy program, it is critical to review carve-out/ineligible claims data from
your TPA system(s) to understand why claims are not qualifying in your 340B program. Carve-
out/ineligible claim data can reveal potential configuration issues or limitations within the TPA system.
Examples include the following:
• Entity-owned pharmacies that have had manufacturer restrictions applied.
• Prescribers or locations that are 340B eligible but are not configured correctly.
• Excluded payers that should be eligible.
• Claims that were not reprocessed after manufacturer pricing was restored.
• Multiple TPA systems are in use, yet the provider files are not consistent among them
If your organization has made any of these mistakes, you are not alone! Keeping up with the complexities
of 340B can be a daunting task – and an administrative burden. Here at Visante, we help grantees,
hospitals and health systems make the most of 340B and optimize their savings. Contact us to learn more
about how we can support all aspects of your 340B program. Email firstname.lastname@example.org or call
(866) 388-7583 to speak to one of our team members.