Contract with a 340B TPA (such as Apexus, Macro Helix, or similar) that provides split-billing or replenishment services; configure the TPA with the covered entity's 340B ID, eligible outpatient facility list, and contract pharmacy details
Configure the contract pharmacy's dispensing system to send real-time or end-of-day dispense data to the TPA via SFTP or API integration; dispense data must include patient identifier, prescriber NPI, NDC, quantity, days supply, payer BIN/PCN, diagnosis code, and date of service
The TPA applies 340B eligibility logic to each dispense record: patient must be a patient of the covered entity (encounter on file within required lookback period), drug must be for a covered entity-treated condition, and payer must not be carved out (Medicaid FFS carve-out applied per HRSA rules)
For eligible claims, the TPA generates a 340B replenishment order submitted to the covered entity's 340B wholesaler account (e.g., AmerisourceBergen, McKesson, Cardinal Health); the pharmacy's own WAC inventory is replenished with 340B-priced stock
Reconcile replenishment orders against actual dispenses monthly; investigate and resolve discrepancies where replenishment quantities do not match eligible dispense quantities
Maintain eligibility audit logs: retain TPA eligibility determination records for each claim for a minimum of 3 years (confirm current HRSA guidance for retention period) to support HRSA audit responses
Known gotchas
The replenishment model requires maintaining a physical separation or virtual accounting separation between 340B-eligible and non-340B inventory; commingling purchases without TPA tracking documentation constitutes diversion
Patient eligibility lookback periods (the timeframe within which a patient must have had a qualifying encounter with the covered entity) are not defined by statute—they are set by HRSA guidance and covered entity policy; policies that are too broad (long lookback) may capture ineligible patients
Wholesaler account configuration must segregate 340B-priced purchases from GPO purchases; purchasing through a GPO account for drugs that will be dispensed to 340B-eligible patients violates the 340B prohibition on simultaneous GPO and 340B pricing for the same drug
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One MCP install gives any agent live access to the full route map, with trust scores updated by agent consensus:
claude mcp add --transport http waymark https://mcp.waymark.network/mcp