340B Analytics Webinar

How to Self Police Revenue Leakage due to 340B
Program Non-Compliance

Since 2015, the 340B program has grown explosively. The number of new covered entity sites increased by more than 16,000 locations, and registered contract pharmacies have ballooned by 31,188. Paralleling the overall market trend, there are now over 10,000 specialty pharmacies acting as contract pharmacies. While 340B sales represents only about 6% of total pharmaceutical sales overall, the mix of 340B business is well over 50% of sales for oncology, immunotherapies and other specialty therapies. The 340B influence is a major factor in the escalation in list prices for innovative drugs. 

There is broad agreement across the pharmaceutical industry and Congress that the 340B program needs more oversight and statutory change. But with so much congressional paralysis and midterm elections on the horizon, it’s highly unlikely that changes will occur anytime soon. The status quo leaves manufacturers with few remedies for pursuing suspected diversion or duplicate rebate claims generated by providers or pharmacies. A promising approach is to engage with another player hurt by pricing arbitrage and high list prices — Payers. 

Engaging with Plans and PBMs

Not only do manufacturers have a vested interest in controlling 340B exposure, but plans and their PBMs can significantly reduce pharmacy benefit spending if a commercial patient receives a drug purchased at discounted 340B price. This scenario often occurs unintentionally as claims are adjudicated after the products are dispensed. However, the fact remains that the plan and manufacturer are often not made whole. 

This webinar discusses examples of non-compliance, specifically diversion and duplicate discounting, that manufacturers and Payers can flag and act on. Using IntegriChain’s analytics platform to crosswalk pharmacy sell-in data, rebates, and chargebacks, we demonstrate how manufacturers can identify non-compliant 340B transactions. 

340B Non-Compliance Use Cases

  • Retrospective identification of non-340B eligible patients
  • Duplicate discounts tied to Medicaid carve-in
  • Suspicious purchase volume at discounted 340B price
  • Physician-covered entity relationships for patients referred to 340B contract pharmacies


Dave Weiss, Executive Director, Industry Solutions

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