340B Strategy, Operations & Program Integrity
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, across operations, clinical practice, regulation and finance.
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 working.
Compliance is table stakes. Plenty of advisors will validate your accumulation, review your policies and tell you whether you would survive an audit — and most of them do that part adequately. It is also the part that stops short of changing anything.
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.
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. Remediation is sold as a cost. Done properly it usually recovers a great deal more than it costs to run.
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.
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.
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.
Operations & workflow
Turning policy into something that runs at the bench. Split billing and accumulator design, purchasing and wholesaler accounts, inventory and dispensing, and the ownership and escalation paths that survive a staffing change.
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
One person who has actually done all four.
This practice is led by a pharmacy director who ran a health system's 340B program from the inside, holding Apexus Advanced 340B Operations certification. Not advising on it — accountable for it.
In practice that meant an Epic go-live, an automated dispensing implementation and a GPO and wholesaler conversion on the operational side. A biosimilar conversion carried through genuine physician resistance on the clinical side. An accepted HRSA corrective action plan and the oversight committee that kept the program compliant on the regulatory side. A pharmacy charge master rebuild on the financial side. 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
Independent of your vendors. Not of your team.
Independence is about who we answer to, not how far away we stand. 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.
No vendor relationships
We do not resell split-billing software, take referral fees, or have a stake in which platform you run. When we tell you a vendor's logic is wrong, there is nothing behind that opinion except the data.
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.