As manufacturer restrictions continue to reshape the 340B landscape, contract pharmacy arrangements remain a critical — yet complex — part of program success. What was once a straightforward extension of pharmacy access has evolved into a more nuanced area of compliance, operations, and financial performance.

In 2025, covered entities need to think strategically about their contract pharmacy partnerships. Whether you’re managing a large network or considering a more targeted approach, now is the time to reassess what’s working — and what’s putting your program at risk.

Below are five best practices to help covered entities optimize their contract pharmacy arrangements in today’s environment.

1. Reevaluate Your Network Strategy

Not all pharmacy relationships add equal value. With increasing pressure from manufacturers and states taking different positions on contract pharmacy access, many covered entities are consolidating networks to reduce exposure and improve oversight.

What to consider:

• Are all your contract pharmacies performing as expected?
• Do they support claims-level data sharing when needed?
• Are there pharmacies you’ve outgrown — or that pose more risk than reward?

A smaller, better-managed network may lead to stronger outcomes than a large, loosely managed one.

2. Review and Refresh Your Contracts

Contract terms set years ago may not reflect current operational realities or compliance risks. Now is a good time to revisit contract language, performance expectations, and revenue share models.

Look for:

• Clauses that allow for real-time data access
• Language that clarifies audit responsibilities
• Flexibility to adapt to ESP or state policy changes

Updating contracts isn’t just about protection — it’s about creating more clarity and control.

3. Strengthen Oversight of Data Flow and Claims Eligibility

One of the most common gaps we see? Missed or misflagged claims due to poor data alignment between the covered entity, TPA, and pharmacy.

Best practices include:

• Ensuring Medicaid identifiers are consistently flagged
• Regular reconciliation between encounter data and claims
• Monitoring for claims that should be eligible but aren’t captured

Data integrity directly impacts savings — and audit readiness.

4. Stay Ahead of Manufacturer and State Policy Changes

More than 20 manufacturers have imposed restrictions on 340B pricing at contract pharmacies. Meanwhile, states like Mississippi and Missouri have passed laws protecting contract pharmacy arrangements — sparking legal pushback from industry groups.

What to track:

• Changes in participation requirements
• State legislation where your pharmacies operate
• Manufacturer-specific carveouts or rebates

Covered entities need to be proactive, not reactive, as the policy environment continues to shift.

Looking Ahead

Contract pharmacies remain a vital part of many 340B programs — but success in 2025 will depend on how well they’re managed. Covered entities that take a strategic, transparent, and data-informed approach to these partnerships will be better positioned to maintain compliance, safeguard program integrity, and maximize the value of 340B savings.

At RxTrail, we work with covered entities to streamline pharmacy relationships, audit data flow, and ensure contract terms align with both compliance and operational goals. If your contract pharmacy model needs a closer look, we’re here to help.

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