For many covered entities, 340B savings are seen as a critical financial lever, but few realize just how much is being left on the table by overlooking referral capture.

Referral claims often represent a significant, untapped savings opportunity. When a patient is referred by an eligible provider to an outside specialist or facility and receives a 340B-eligible medication as part of that care, those prescriptions can potentially qualify under the program. But if your systems and processes aren’t built to identify and capture those claims, those savings quietly disappear.

Why Referral Capture Often Falls Through the Cracks

There are a few reasons referral claims go unclaimed. In some cases, internal workflows aren’t set up to track provider referrals in a way that ties back to patient eligibility. In others, TPAs or contract pharmacies lack the system integrations or data access needed to match those referrals to 340B-qualified prescriptions. And in many organizations, no one owns the process end-to-end.

This isn’t just a compliance issue, it’s a revenue one. We’ve worked with clinics and hospitals that were missing six figures annually in savings, simply because they weren’t tracking referrals effectively or didn’t have a defined workflow for capturing these claims.

Key Requirements for Compliant Referral Capture

To capture referral claims with confidence, covered entities must meet several core requirements. HRSA has consistently reinforced the following standards:

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1. Ownership & Documentation of Patient Care

The covered entity must maintain responsibility for the patient’s overall care. This is the foundation of HRSA’s patient definition. The prescribing provider does not need to be employed by the covered entity, but the CE must be able to demonstrate that the patient is under its care and the referring relationship is documented in the patient charts (i.e. by referral, mention of specialist in patient visit notes, and the medication mentioned).

2. Written Policies and Procedures

Covered entities must have formal, written policies outlining how referral claims are managed and processed within the 340B program. These policies should address the conditions under which referral claims are eligible, the documentation required, the audit and reconciliation process, and which departments or staff members are responsible for each step.

Why Referral Capture Matters More Than Ever

As contract pharmacy margins compress and manufacturers shift toward rebate-based models, referral capture has become one of the most impactful ways to recover lost 340B savings. However, this opportunity is only accessible if your organization is equipped with the right documentation, workflows, and oversight.

Many covered entities have the right intent, but lack the structure to implement referral capture in a way that would withstand audit scrutiny.

How RxTrail Can Help

At RxTrail, we help covered entities build and implement referral capture systems that are audit-ready, fully documented, and designed to maximize 340B savings. From policy creation and EHR documentation workflows to TPA coordination and quarterly audit simulations, we ensure you're positioned to capture every eligible claim, without increasing risk.

Referral capture isn’t a gray area, it’s a missed opportunity for programs that aren’t set up to execute it properly. With the right framework in place, it can become a reliable and compliant source of revenue recovery.

If you're ready to unlock the full potential of your 340B program, let's start with your referrals.

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