Understanding 340B Eligibility & Referrals

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Understanding Referrals and 340B Eligibility: A Comprehensive Guide by FQHC 340B Compliance

Referrals play a crucial role in the 340B Program, and there's often confusion surrounding their eligibility. As a leading authority in the healthcare industry, FQHC340B Compliance aims to clarify the intricacies of referrals and their status within the 340B Program. It is important for health centers to be educated on the guidance provided by the Health Resources and Services Administration Office of Pharmacy Affairs (HRSA OPA) and how to determine if a prescription associated with a referral is 340B eligible. In addition, it is beneficial to gain knowledge on the best practices for handling referrals and to recognize the importance of regular audits to ensure compliance.

Defining 340B Eligibility for Referrals

The basis for referral inclusion in the 340B Program lies in HRSA's 1996 patient definition. According to this definition, to be considered 340B eligible, a patient must meet certain criteria.

First, they must be a patient of the covered entity, and the entity should maintain records of their care. Second, the patient must receive services from a healthcare professional who is either employed by or contracted with the covered entity, including those under a referral for consultation. Third, the covered entity must be able to demonstrate ongoing responsibility of care for the individual, consistent with the scope of the grant.

Training Staff for Successful Referral Capturing

To ensure the successful capturing of referrals within the in-house pharmacy, proper training of staff is critical. Staff members must be familiar with the340B Program's criteria for eligible referrals before processing any claims.One effective method used in the 340B Program is categorizing by distinguishing between internal prescribers and referral providers. This categorization facilitates the audit process, allowing the focus to be on claims from external providers.

Customizing Referral Processes

FQHC 340B Compliance emphasizes the importance of customizing referral processes to align with the organization's practices. Tailoring the process ensures that referrals are handled efficiently and in compliance with the organization's policies and procedures. It is crucial to address key aspects such as the shelf life of referrals and whether a note back from the specialist is a mandatory standard for 340B eligibility.

Auditing Referrals for Compliance

Given the complexities surrounding referrals, it is paramount for health centers to conduct monthly audits to maintain compliance with the 340B Program. During these audits, health centers should verify the presence of an outgoing referral, demonstrate ongoing responsibility of care for each prescription, and ensure that patients remain active within the health center.

Addressing Patients Already Established with a Specialist

When a patient is already receiving care from another prescriber, HRSA auditors are looking for an outgoing referral from the health center. To address this scenario, FQHC 340B Compliance suggests documenting any specialist relationships with a referral for consultation when new patients are established. Additionally, using a designated field within the pharmacy software to identify existing referrals can help avoid the need for repeated verification.

Understanding referrals and their 340B eligibility is essential for covered entities participating in the program. FQHC340B Compliance stresses the significance of adhering to HRSA's patient definition and provides insights into best practices for capturing referrals and conducting regular audits. By following these guidelines and customizing referral processes, health centers can navigate the complexities of the 340B Program effectively, ensuring compliance and providing optimal care to patients. Don’t let the 340B eligibility and referral process for your health center weigh you down! Reach out to our team of experts today.


FQHC340B Compliance is the dedicated partner for Federally Qualified Health Centers seeking assistance with the 340B Program. Their mission is to provide the necessary resources to secure and optimize the 340B Program, enabling health centers to offer more comprehensive services to those in need. With a focus on improved compliance and oversight, they act as more than just consultants or automated systems, tailoring their services to meet your health center's unique needs. Visit their website, call (760) 780-7469, or email to learn more about FQHC 340B Compliance and how they can help your health center thrive.

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