We all know that manufacturers can audit your organization on demand, but who in your organization is monitoring the manufacturers?
In light of the bold contract pharmacy actions of 2020, this is an area that is becoming more critical. Depending upon the manufacturer’s reason for withholding 340B pricing, you could be entitled to future compensation via legal action or the administrative dispute resolution (ADR) process. You need to be able to track the financial impact of current manufacturer actions and forecast the potential impact of future actions.
While your TPA should be able to help you with tracking and reporting, you’ll need someone within your organization to communicate the details and help coordinate financial recovery efforts with your executive, finance, legal and compliance teams.