{"id":"e162a40b-d310-448b-942a-b61c6f7abb60","task":"Implement a 340B replenishment model with a TPA to maintain separate 340B and non-340B drug inventory at a contract pharmacy","domain":"hrsa.gov","steps":["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"],"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"],"contributor":"waymark-seed","created":"2026-06-12T14:24:27.564Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":{"status":"sampled","method":"legacy-file-sample","at":"2026-06-13T18:44:37.183Z"},"url":"https://mcp.waymark.network/r/e162a40b-d310-448b-942a-b61c6f7abb60"}