340B & Pharmacy Program Strategy
Come and see what your program could be.
An invitation, not a pitch. We work alongside your team — the same records, the same meetings, shared ownership — taking a 340B program from where it is to where it should be, and following the money out into the contracts, purchasing and processes that decide what it is ever worth.
The invitation
Come and see.
The name comes from the Gospel of John. Philip tells Nathanael he has found the one the prophets wrote about, and Nathanael is openly skeptical. Philip doesn't argue the point or press his credentials. He says: come and see.
That is how we prefer to work. Come alongside, look at the same records, learn the method while it is being built. Nobody is asked to trust a black box — what gets understood is shared, and so is the ownership.
And it matters because of what sits underneath it. 340B exists so that safety-net providers can stretch scarce resources further for the patients who need them most. Every qualifying unit that fails to accumulate is care that doesn't get funded.
The real gap
Compliant is not the same as optimized.
Plenty of advisors will check your accumulation, review your policies and tell you whether you would survive an audit — and most of them do that part well enough. But passing an audit only proves you did not break the rules. It says nothing about whether the program is capturing what it should, whether the workflow is one your team can actually execute, or whether it produces the same result the next time somebody runs it.
What we see far more often than non-compliance is a program that is technically fine and quietly underperforming. Savings that were always available and never captured. Workflows that exist on paper and not at the pharmacy bench. Policy decisions nobody can reconstruct two staff changes later. None of that shows up as a finding, and none of it fixes itself.
Compliance is the foundation. Nobody pours a foundation and stops — but that is where most 340B engagements end, because a clean audit is the easiest thing to invoice for and the easiest thing to prove.
Closing a finding and capturing missed savings turn out to be the same work — rebuilding eligibility, reconciling accumulation, checking what was purchased against what actually qualified, working the credit rebills nobody chased. The difference is whether anyone keeps going once the box is ticked. That second half is where the money is, and it is the half we are actually here for.
Some of it is also on a clock. Credit rebills generally cannot reach back beyond a hundred and eighty days, and none of them are guaranteed. A purchasing error found this month may still be correctable. The same error found next year is simply a loss the organization has already absorbed without noticing.
What makes us different
340B sits where four disciplines meet.
Most advisors work in one of them, occasionally two. That is where programs come apart — because a decision taken in one breaks something in another.
Operational
Split billing and accumulator design, purchasing and wholesaler accounts, inventory and automated dispensing, contract pharmacy administration. The daily mechanics that decide whether a policy survives contact with the pharmacy bench.
Clinical
Formulary and therapeutic interchange, biosimilar conversion, site of care and drug selection, and the physician engagement any of it depends on. 340B decisions are clinical decisions before they are financial ones.
Legal & regulatory
Eligibility and status determination, the GPO prohibition, Medicaid carve-in versus carve-out, HRSA audit and corrective action, oversight committee structure and the documentation that has to outlive the people who wrote it.
Financial
Savings modeling, purchasing optimization, charge master and billing accuracy, budget impact, and board-level reporting that holds up when finance starts asking where the number came from.
In a hospital there is no such thing as a purely financial decision. Move any one of these four and the other three move with it, whether anyone accounts for them or not. A formulary decision reshapes accumulation. A purchasing decision can create a duplicate discount. A policy that reads well on paper becomes unworkable at two in the morning.
Not seeing those effects does not prevent them. It only means nobody is addressing them.
Scope
340B is the doorway, not the boundary.
A 340B program can be run correctly and still leave the organization underperforming, because the program does not control most of what determines the result. It does not set the price of the drug — the GPO contract does. It does not decide which account a purchase lands in — the purchasing and inventory process does. It does not ask whether the aggregation group you joined three years ago still fits the volume you buy today, or whether a compounded dose is billed for what it actually is.
Optimize the program by itself and you have optimized a slice. The decision that moves more money than anything inside the program gets made in a different department, on a different day, by people nobody told it mattered. Most of what an organization loses is lost in the space between two departments that each did their own job correctly.
So the work follows the whole equation wherever it leads — GPO contracts and tier performance, aggregation group fit, wholesaler terms, purchasing account structure, inventory and par levels, compounding and waste, charge capture, and the collaboration between departments and roles that decides whether any of it holds.
Cost of goods as low as it can go. Revenue actually collected as high as it can go. The best outcome the patient can get. All at the same time.
And all of it inside every legal and regulatory requirement, without breaking a single commitment the organization has already made to a GPO, an aggregation group or a wholesaler.
Any one of those is easy on its own. Cost comes down if you stop caring about outcomes. Revenue goes up if you stop caring about the rules. The difficulty, and the entire job, is that all of them have to be true at once.
Capabilities
What we take on
Most engagements begin with one of these and few of them stay there. The work follows the problem into whichever disciplines it turns out to touch.
Reading this from outside pharmacy? The short version: 340B is a federal drug pricing program, the savings are material to a hospital's margin, and most of the ways it goes wrong stay invisible until somebody audits them.
Program assessment
An honest baseline across all four disciplines: what the program captures today, what it leaves behind, where it is exposed, and which of those actually matters first. Not a compliance checklist with a score at the end.
Savings capture & optimization
The part most reviews skip entirely. Eligibility breadth, child sites and contract pharmacy, purchasing across 340B, GPO and WAC, and the accumulation that quietly never happened — recovering what the program was always entitled to.
Drug spend, contracts & aggregation
The cost side, most of which sits outside the 340B program and decides what the program can ever be worth. GPO contract and tier performance, aggregation group fit, wholesaler terms, purchasing account structure, inventory and compounding waste.
Operations & workflow
Turning policy into something that runs at the bench. Purchasing and wholesaler account structure, inventory and automated dispensing, contract pharmacy administration, and the ownership and escalation paths that survive a staffing change.
Data, analytics & reconciliation
Accumulator design and validation against your own source data, reconciliation of TPA output against source charge and encounter data, claims and data submission support, and the NDC and RxCUI crosswalks that decide whether any of it ties out.
TPA & software implementation
Selection, transition, and getting an implementation actually right — verifying setup and configuration, then verifying what almost nobody checks: that the data going in and the data coming out are what everyone assumes they are. Which system a feed is pulled from, by which method, from which field, quietly decides whether the output is correct.
Clinical integration
Formulary and therapeutic interchange, biosimilar conversion, site of care and drug selection — and the physician conversations every one of those depends on. 340B decisions fail clinically long before they fail financially.
Eligibility, GPO & Medicaid
Patient and encounter eligibility, inpatient versus outpatient status, the GPO prohibition, Medicaid carve-in versus carve-out, and keeping registrations and the exclusion file consistent with what the organization actually does.
Audit readiness & remediation
Self-audit, HRSA audit response and corrective action, and documentation that traces every conclusion back to a record — written so it outlives the people who wrote it.
Who you're hiring
Led by someone who has actually done all four.
This practice is led by a pharmacy director who has run 340B programs from the inside at two health systems — first as assistant director, then as director — holding Apexus Advanced 340B Operations certification. Not advising on it. Accountable for it.
Those were different covered entity types, which matters more than it sounds. The GPO prohibition binds a disproportionate share hospital and not a sole community hospital; the orphan drug exclusion runs the other way. He has run programs under both, and consults across rural referral centers, Ryan White programs and FQHCs — designing them, optimizing them, and bringing them into compliance. Advice built on one entity type does not transfer cleanly to another.
On the financial side that has meant a pharmacy charge master rebuild and co-leading the PBM negotiations after spotting the opportunity nobody had priced. On the operational side, an Epic go-live, an automated dispensing implementation, a GPO and wholesaler conversion, and co-developing inventory optimization software with a manufacturer. On the clinical side, a biosimilar conversion carried through genuine physician resistance, and a ready-to-use conversion that cut drug waste and nursing time while freeing cabinet capacity. On the regulatory side, an accepted HRSA corrective action plan, the 340B oversight committee he built and co-chaired with the chief financial officer, and a later HRSA audit that is on the public record. Several of them running at once.
Advisors who have only ever worked one of those four tend to produce recommendations that fail in the other three. More about the background →
How we work
Alongside your team, not across the table.
The invitation is not only how an engagement starts. It is how it runs. We don't parachute in, hand over a deck, and leave the hard part to you.
Ownership, not observation
Give us a piece of the program and it stops being your problem and becomes ours — we sit in the meetings, carry the actions, and answer for the numbers. Consultants study someone else's problem from a safe distance and move on once the findings are delivered. Most of the useful work happens after the findings, and that is the part we stay for.
Source data or nothing
Every finding traces to a record in your systems. We will tell you when the data cannot support a conclusion rather than producing a confident number that will not survive scrutiny.
You keep the method
The method gets taught while it is being built, not handed over as a finished artifact — your team watches it come together and can rerun the analysis once we are gone. The goal is a capability that stays with you: a partnership that makes itself optional, rather than a retainer that makes itself permanent.
Come and see where the road leads.
Tell us what you are seeing — a savings number that looks off, an audit on the calendar, a TPA transition. We will tell you honestly whether it is worth an engagement.