It is possible to utilize the 340Better program if your health center is contracting with retail pharmacies ("bill to/ship to"). The health center must purchase the drugs and then the drugs are shipped to a contracted retail pharmacy. The health center and retail pharmacy need to be registered with the Office of Pharmacy Affairs (OPA). Here is a checklist of items that need to be observed when working with a contracted retail pharmacy:
- Register the contracted retail pharmacy (hyperlink)
- Responsibilities (hyperlink)
- Audit requirements (hyperlink)
Register the contracted retail pharmacy
When registering a contracted retail pharmacy, the same OPA Registration Periods apply as when registering a health center site. If a contracted retail pharmacy is not yet registered with the OPA, please register online. There are only four 15-day windows a year (each calendar quarter) for a health center to add a new clinic site or contracted retail pharmacy to the OPA database. The registrations are then effective the next calendar quarter. The following deadlines are for enrolling NEW contracted retail pharmacies for 340B pricing:
| Registration Period: |
Oct 1-15 |
Jan 1-15 |
April 1-15 |
July 1-15 |
| Start Date: |
Jan 1 |
April 1 |
July 1 |
October 1 |
Sign Up Now!
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Click here to complete the OPA online registration process for contract pharmacy services.
- To sign up for the 340Better pharmacy program email [email protected].
- TACHC will then coordinate with Cardinal to establish a Cardinal account for the health center and will be back in touch with the designated point of contact for next steps.
- Certification of the existence of a 340B contracted pharmacy services arrangement is completed electronically. The Drug Enforcement Agency (DEA) pharmacy registration database and the OPA 340B contracted pharmacy database are integrated. When a health center registers a contracted pharmacy online, it will be prompted to search by DEA number for the pharmacy. If the health center does not know the pharmacy’s DEA number, or if the pharmacy does not have a DEA number, the health center can still search for the pharmacy by name, city, state and/or zip code.
- If a health center needs to terminate a contracted retail pharmacy arrangement, there is a direct link on the OPA database.
Responsibilities
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Health centers along with contracted retail pharmacies are responsible for ensuring compliance with all 340B requirements to prevent diversion and duplicate discounts.
- Both parties must agree that they will not resell or transfer a 340B drug to any party but health center patients.
- Both parties must also establish an arrangement with the state Medicaid agency to prevent duplicate discounts.
- Both the health center and the contracted retail pharmacies must adhere to all federal, state and local laws.
- All health centers are required to maintain auditable records and it is the expectation of HRSA that most health centers will utilize independent audits as part of fulfilling their ongoing obligation of ensuring compliance. However, HRSA leaves it up to the health centers to determine how to meet their compliance responsibilities.
Audit Requirements
To the extent that any internal compliance activity or audit performed by a health center indicates that there has been a violation of 340B program requirements, HRSA expects that such finding be disclosed to HRSA along with the health center's plan to address the violation. Auditable records need to be maintained for a period of time that complies with all applicable federal, state and local requirements.