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  • Lyssa Limbrecht

Better Together: Building a Successful 340B Program

Imagine opening and running a restaurant with no experience or resources.


For sure, it’s a huge commitment that involves getting proper licensing and permits, dealing with multiple vendors, managing a team, and so on.


Here’s the thing. Launching and running a 340B program is like opening and running a restaurant. How so?


They both need large amounts of planning and dedication to function and grow. And without these in place, financial success and regulatory compliance can get out of control fast.


For what it’s worth, successful 340B programs carry out well-planned launches.


That’s why, before launching, a best practice is to create a 340B committee. In fact, HRSA expects you to create a team with defined roles that will oversee your 340B program.


Your committee members should come from multidisciplinary backgrounds and senior leadership. Departments to choose from includes:

● Finance

● Information Technology

● Legal

● Compliance

● Pharmacy


A diverse team will help you better optimize your program as they bring their unique skills and perspectives to the table.


Proactive engagement from your committee at the start and onwards is super important. A couple of benefits include higher compliance and less uncertainty.


340B committee responsibilities involve:

● Creating and approving 340B policies and procedures

● Providing 340B self-audit oversight and documenting any findings

● Choosing the right technology to administer and manage your program

● Tracking and documenting financial transactions and health of your program.

● Managing patient and provider data on an ongoing basis.

● Developing 340B education materials for staff members involved in your program


This is not an exhaustive list. The general rule is to structure your oversight committee in a way that works best for your organization. How to keep your committee fully engaged?


Hold at least quarterly meetings featuring extensive reviews of your program’s:

● Compliance

● Financial performance

● Problems & their solutions

● Operations and more


Use these meetings to update your committee on regulatory changes that could affect how your program operates.


Keep minutes for your quarterly meetings plus any records of findings, with any resolutions you made. Why? HRSA asks for this information during audits.

Key Takeaways

● Create a committee. HRSA expects you to, plus it helps you manage your program.

● Pick committee members from multidisciplinary backgrounds and senior leadership.

● Keep minutes of your meetings and records of your findings including any changes made.


Where do you go from here?


Resources like 340B Univ. OnDemand and Live will help your team stay up to date now and into the future. Consider outsourcing many of your 340B day-to-day tasks with a 340B specialty consultancy.


This does not remove your facility’s responsibility to oversee the program but can GREATLY help to minimize the time you spend on little tasks, while maintaining the best, most compliant 340B Program possible.


Questions? Concerns? Comments? Reach out to Lyssa at 208-860-2157 or Lyssa@Optimal340B.com.




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