IconIcon

Top 4 Mistakes We See with Lack of Visibility in 340B

November 13, 2025

And How They’re Costing Covered Entities Compliance, Savings, and Time

A strong 340B program isn’t just about having the right software in place, it’s about having visibility. When covered entities can’t see what’s really happening across their TPAs, contract pharmacies, and referral networks, small issues can quietly become costly ones.

Here are the top four mistakes we see when 340B programs operate without full visibility, and how to fix them.

1. Missed Claims and Uncaptured Revenue

When data isn’t flowing seamlessly between the TPA, pharmacy, and wholesaler, it’s easy for eligible claims to slip through the cracks. Many entities assume their TPA “catches everything,” but visibility gaps often mean:

  • Duplicate or incomplete prescriber lists
  • Missed referral claims
  • Delayed replenishment or incorrect accumulator data
  • Missing and/or gaps in encounter feeds - these are feeds entities send to their TPA to gain clarity on which patients are seen at certain entities

Each missed claim represents lost revenue, and when scaled over time, those small gaps can equal hundreds of thousands in forfeited revenue.

How to fix it:
It is important to make sure you have properly connected all your data sources. Real-time visibility lets your team identify mismatched records and ensure every eligible claim is captured. 

2. Reactive Rather Than Proactive Compliance

Without clear visibility into what’s happening across your 340B program, compliance efforts tend to be reactive. Many covered entities only discover problems after an audit alert or invoice discrepancy, at which point it’s too late to correct the record.

Common blind spots include:

  • Untracked contract pharmacy performance
  • Not keeping provider lists up to date
  • Mismatched CE/TPA data feeds
  • ESP submission errors that go unnoticed
  • No systematic audit trail of rejected or disputed claims

How to fix it:
Implement proactive monitoring and reporting workflows. When your program has automated alerts and transparent tracking, your team can resolve issues before they turn into audit findings or lost revenue.

3. ESP Submission Errors and Manual Overload

This is one of the biggest mistakes we see with partially managed or under staffed programs. Many covered entities believe they can manage ESP or other manufacturer submissions internally, until the first wave of errors appears. This is something we saw with ESP and something we are trying to be proactive about for the upcoming 340B Rebate Beacon change happening January 1st.

Without experience in formatting data files, resolving manufacturer rejections, or handling Beacon system updates, teams quickly find themselves overwhelmed.

What starts as a “we can handle this” project becomes a cycle of resubmissions, disputes, and uncertainty about whether rebates are being received correctly.

What this looks like:

  • Frequent ESP file upload errors or data mismatches
  • Misunderstanding of rejection reasons or status codes
  • Time spent chasing manufacturer responses
  • Delayed or lost rebate payments

How to fix it:
Partner with a team experienced in both ESP and Beacon workflows. The right management solution automates submissions, tracks rejections, and ensures that every rebate-eligible claim is reconciled properly, saving time and preventing compliance exposure.

4. Reactive Compliance and Fragmented Oversight

The 340B program is complex, with constantly changing rules, manufacturer updates, and payer carve-ins and carve-outs to keep up with. When multiple systems and vendors are involved, it’s easy for covered entities to lose track of who’s responsible for what. That’s when compliance becomes reactive instead of proactive.

Common issues:

  • No clear systems for submissions or disputes
  • TPA and CE data feeds that don’t align
  • Missed updates to state or manufacturer requirements
  • Limited visibility into referral claims and contract pharmacy activity

How to fix it:
Create a single source of truth for your 340B program. Integrated dashboards and managed oversight give your team the ability to track every transaction, resolve issues early, and operate confidently under HRSA and manufacturer requirements.

Related Content