Register the covered entity on the 340B ESP platform (free for covered entities) at 340besp.com; designate an administrator and configure the entity's 340B ID and contract pharmacy list
Export contract pharmacy dispense data from the TPA or split-billing system in the format required by 340B ESP (typically a structured CSV or EDI file containing de-identified claim records including drug NDC, date of service, quantity, days supply, payer type, and claim identifier)
Use 340B ESP's proprietary de-identification process: PHI is stripped and encrypted client-side before upload; the resulting de-identified dataset is linked to manufacturer Medicaid and commercial rebate data for duplicate discount matching
Upload the de-identified claims file through the 340B ESP secure portal or API; receive a confirmation receipt with upload timestamp and record count for reconciliation
Monitor 340B ESP for notifications from participating manufacturers requiring claims data; respond to data requests within the manufacturer's stated window to maintain access to 340B pricing from that manufacturer
Retain upload receipts and matching reports as compliance documentation; HRSA audit inquiries and manufacturer dispute resolution processes reference these records
Known gotchas
Participation in 340B ESP is voluntary for covered entities but some manufacturers have conditioned 340B pricing at contract pharmacies on covered entity participation in 340B ESP or the manufacturer's own equivalent program; non-participation may result in loss of 340B pricing for that manufacturer's products at contract pharmacies
340B ESP de-identification is based on an Expert Determination under HIPAA Safe Harbor; if a covered entity uses a different de-identification methodology or uploads non-de-identified data, it may create a HIPAA breach risk
The platform only addresses duplicate discounts for manufacturers who have enrolled in 340B ESP; for manufacturers not on the platform, covered entities must maintain separate duplicate discount prevention processes (typically Medicaid carve-out)
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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