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Hospital outlines 340B compliance work and seeks to recoup nearly $800,000 after Cerner rollout
Summary
Pharmacy leadership told the compliance committee the hospital completed a carve‑in for inpatient 340B after Cerner went live, is pursuing about $800,000 in credit rebills tied to earlier Cerner reporting gaps, and plans contract pharmacy signups while monitoring a forthcoming HRSA rebate‑pilot notice.
Pharmacy leadership told the Hospital Authority Compliance Committee the hospital is actively managing its 340B compliance program and pursuing significant recoveries tied to Cerner implementation delays.
"340B is a federal program that allows us to purchase medications at a significantly reduced rate based upon usage," Dr. **** said, explaining that eligibility requires the right patient, provider, visit and medication to align. She described a carve‑in for Medicaid/TennCare patients that went live Jan. 1 on the inpatient side and said outpatient specialty work remains in progress.
Dr. **** said the hospital is trying to reclaim roughly $800,000 in WACC (wholesaler acquisition cost) credit rebills after Cerner reports failed to capture required data at go‑live. Pharmacy staff worked with Cerner over several months to rebuild reporting and have recovered about half of the targeted amount so far.
The hospital has also contracted with auditing/vendor partner VSANT to perform 340B compliance audits and signed or is signing contract pharmacies to capture prescription volume filled outside hospital pharmacies. Pharmacy staff warned of possible national changes: HRSA has issued notice in the Federal Register about a rebate pilot that could change how manufacturers rebate 340B‑eligible purchases; the pilot could take effect next year unless overturned.
Board members emphasized the patient impact of 340B savings — citing improved access to blood‑pressure medicines and chemotherapy for patients who otherwise could not afford them — and thanked pharmacy staff for salvaging savings after the Cerner rollout.
Next steps: pharmacy will continue contract pharmacy signups, pursue outstanding credit rebills, monitor HRSA developments, and present further program updates to the board.
