7 Bad Habits That Could Lead To Failing a 340B HRSA Audit (Chris Hatwig weighs in)

September 12, 2017

Chris Hatwig, the president of Apexus, the HRSA-designated prime vendor for the 340B Drug Pricing Program, noted that his experience with 340B dates back to his tenure at Parkland Hospital, in Dallas, during the program's infancy in the early 1990s. "Our CFO testified before Congress to get this program approved, and back then it was just a pharmacy program; the pharmacy director was expected to figure it out and implement it. But it's no longer just a pharmacy program; it's too critical to the eligible entities. First and foremost, you have to recognize what types of resources to put in place [to ensure compliance]. For smaller covered entities, this can be a particular issue."

Due to the "incredible complexity" of the 340B program, Mr. Hatwig advised covered entities to involve the C-suite, as well as finance, compliance, legal and pharmacy. "Leadership needs to understand that there will need to be resources dedicated to making this work," he said.

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