From wherever the program is, to where it should be.

Before recommending anything we establish what the program is actually doing — across all four disciplines, not just the compliance one. What it captures, what it leaves behind, where it is exposed, and how each of those interacts with the others.

The output is a prioritized picture rather than a score. Most assessments produce a list of findings ranked by severity. That is not the same as knowing what to do first, and it is the ranking that determines whether anything actually changes.

The work most reviews never get to. Eligibility breadth across departments and child sites, contract pharmacy performance, purchasing split across 340B, GPO and WAC, credit rebills nobody went back for, and the accumulation that quietly never happened because two systems never agreed on a join key.

None of this appears as a finding. Nobody is out of compliance for failing to capture savings they were entitled to. It simply does not happen, year after year, until somebody goes looking.

Part of it is also time-limited, which is the argument for looking sooner rather than at some tidier moment. Credit rebills generally cannot reach back beyond a hundred and eighty days, and none of them are guaranteed. Every month that passes quietly converts a recoverable purchasing error into a permanent one.

The cost side of the equation, most of which sits outside the 340B program and quietly decides what that program can ever be worth. GPO contract and tier performance against what was actually agreed, aggregation group fit as volume shifts, wholesaler terms and cost-plus structure, purchasing account setup, inventory and par management, and the compounding and waste decisions that move more dollars in a year than most contract negotiations do.

This is a separate question from the GPO prohibition, which is a compliance matter covered further down. This one is commercial: whether the organization is getting what it agreed to, and whether what it agreed to still fits what it now buys.

It is also where the silo does the most damage. Pharmacy, supply chain, finance and revenue cycle each optimize their own piece, every decision is defensible on its own terms, and the organization still ends up with a worse result than any of them intended.

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 decide whether any of it survives a staffing change.

A policy nobody can execute at two in the morning is not a policy. This is the difference between a program that is defensible on paper and one that works.

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 and catalog normalization that decide whether any downstream number ties out.

This is the layer nobody presents in a board meeting and everything else depends on. When a savings report is wrong, the cause is usually here — an eleven-digit NDC normalized inconsistently, a package basis applied at the wrong unit, two systems that never agreed on a join key.

Selecting a third-party administrator or platform, migrating to it, and getting the implementation right rather than merely finished. We verify the setup and the configuration settings, and then verify the part almost nobody checks: that the data feeds going in and the outputs coming back are actually what everyone assumes they are.

Most teams have never had reason to interrogate their own data. Which source system an extract is pulled from, by which method, from which field — each of those quietly determines whether the output is correct, and none of them announce themselves when they are wrong. A go-live or a transition is precisely when accumulation breaks, and precisely when nobody is watching for it.

Formulary and therapeutic interchange, biosimilar conversion, site of care and drug selection — and the physician engagement that every one of those depends on.

This is the discipline most 340B advisors have no standing in, and it is where the largest decisions are actually made. A conversion that finance loves and the medical staff will not accept produces nothing. Clinical failure precedes financial failure every time.

Patient and encounter eligibility, inpatient versus outpatient status determination, the GPO prohibition for covered entity types subject to it, Medicaid carve-in versus carve-out and how that interacts with your state's billing rules.

Also the unglamorous half: keeping OPAIS registrations, child site listings and the Medicaid Exclusion File consistent with what the organization actually does today rather than what it did when someone last updated them.

Self-audit, HRSA audit response, corrective action plans, and documentation that traces every conclusion back to an underlying record. We work the way an auditor works: sample, follow the record end to end, see whether the trail holds.

And remediation is not only a cost. The work that closes a finding — reconstructing eligibility, reconciling accumulation, checking purchases against what qualified — is the same work that surfaces volume you were entitled to and never captured. Properly run, it recovers considerably more than the exposure that prompted it.