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Maximizing 340B in Response to COVID-19

The COVID-19 pandemic has impacted nearly every aspect of healthcare, including the 340B drug pricing program. The Health Resources and Services Administration (HRSA) is working diligently to keep covered entities updated on the latest information regarding COVID-19 and its impact on 340B. In response to the pandemic, HRSA is now allowing some hospitals to immediately enroll in 340B upon request and review in order to reach more eligible patients with lower priced drugs for their underserved patient population.

Since the outbreak began, HRSA[i] has made some accommodations for COVID-19’s impact while holding firm on other rules.

HRSA Updates

Expanding to additional sites

Covered entities seeing a surge in patients may need to expand 340B services to an additional site. HRSA will evaluate each hospital circumstance on a case-by-case basis. To ensure that the additional offsite facility is reimbursable, HRSA must first verify that the facility is listed as reimbursable on the hospital’s most recently filed Medicare cost report and has associated outpatient costs and charges as outlined in HRSA’s 1994 Outpatient Hospital Facility Guidelines.


HRSA recognizes that covered entities may need to offer telehealth services for their 340B population. HRSA recommends that hospitals outline telepharmacy modalities in their policies and procedures and continue keeping auditable records for each patient who receives a 340B drug.


HRSA is continuing to conduct 340B audits for covered entities remotely (i.e., virtually) for the next several months while the organization assesses the impact on hospitals participating in the program.

Getting the most from 340B

Comprehensive Pharmacy Services (CPS) has been delivering trusted 340B support to covered entities since the program began in 1992. Our team of 340B experts know how to help covered entities navigate the changing dynamics in healthcare to stretch federal resources and stay compliant with HRSA requirements. Our 340B team can help keep your facility up-to-date and deliver results. We’ll help your organization:

Optimize savings

Many times, covered entities don’t have the resources to identify and implement savings. CPS can support your organization both onsite and remotely through high intensity training, identifying risks, prioritizing tasks and more so you are meeting HRSA standards and serving your patient population.

Prepare for audits

Audits are going to happen, even in the COVID-19 environment. CPS 340B experts will perform an extensive independent review of all 340B elements to ensure compliance. Our team will perform comprehensive mock audits to identify where your organization may not be in compliance and then draft actions to get into compliance.

Maintain a state of continual readiness

The CPS 340B team of experts will ensure that you have a robust program in place with compliance support to keep you in a state of continual readiness for the inevitable audit. Our 340B specialists will follow up with your team regularly to ensure that you have the guidance and action plans to stay compliant and adjust to changes in HRSA policy and requirements.

Your partner for long-term 340B success

No matter what challenges surface along the way, the CPS 340B team supports your organization by staying ahead of the curve and monitoring the latest guidance. Our team is experienced with all types of 340B programs, including large health systems, DSH, CAH, FQHCs, Ryan White and Hemophilia programs. We know the HRSA standards inside and out. Our 340B team members are graduates of 340B University, and we even have a former board member of 340B Health on our staff.

To learn more about how CPS can help your organization maximize your 340B program, contact us: or visit: 

340B solutions


[i] Accessed 6.15.20.

Posted: Friday, June 19, 2020

Tags: Blog