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340B Implementation

Once a covered equity is enrolled in the 340B Program and included in the covered entities database, it is the covered entity's responsibility to inform wholesalers and manufacturers of enrollment in order to purchase drugs at the 340B discounted price.

Covered entities may continue to work directly with individual wholesalers and manufacturers and may participate in the 340B Prime Vendor Program (PVP). As the government's awarded 340B Prime Vendor, Apexus is responsible for securing sub-ceiling discounts on outpatient drug purchases and discounts on other pharmacy related products and services for covered entities electing to join the PVP. For complete information, see the Prime Vendor Program .

Implementation Options

HRSA does not specify how participants should implement the 340B Program. As long as participants comply with all 340B Program requirements, they have flexibility in implementing the 340B Program.

Most covered entities choose one or more of the following options:

• In-House Pharmacy, in which the covered entity owns drugs, pharmacy and license; purchases drugs; is fiscally responsible for the pharmacy; and pays pharmacy staff.
• Contract Pharmacy Services, in which the covered entity owns drugs; purchases drugs; pays (or arranges for patients to pay) dispensing fees to one or more contract pharmacies; and contracts with pharmacy to provide pharmacy services.
• Provider/In-House Dispensing, in which the covered entity owns drugs; employs providers licensed in the state to dispense; holds a license for dispensing for the participating providers; and is fiscally responsible for operating and dispensing costs.
• Alternative Methods Demonstration Project, in which HRSA Office of Pharmacy Affairs approves a model proposed by the covered entity, such as a network of 340B covered entities.