The purpose of an external audit is to accurately identifying any possible discrepancies or inconsistencies and offer solutions to ensure the highest 340B program standards. Ensuring compliance, protects the integrity of the 340B program in general and the safety net community.

What about eligibility?

Duplicate Discounts

Prescriptions may not be filled with 340B drugs and also be submitted for a manufacturer rebate by the state[deleted extra clause]. This is considered a duplicate discount and is prohibited by section five of the 340B statute. Each entity is urged to understand any state restrictions or billing requirements for use of 340B drugs for Medicaid patients.

If the entity decides to use 340B drugs for any Medicaid patients they must:

Medicaid Managed Care

HRSA has clarified that all their policies and information entered in the HRSA Medicaid Exclusion file are specific only to Medicaid FFS, not Medicaid MCO. A conservative approach is that an entity using 340B drugs for Medicaid MCO patients should work with the state to ensure that no duplicate discounts are created.