While TPAs provide essential infrastructure, it’s important to remember that covered entities are still responsible for compliance. A TPA is a tool, not a shield. If something goes wrong (e.x. ineligible claims, missing documentation, or ESP noncompliance), HRSA will hold the covered entity accountable, not the TPA.

A TPA is a vendor that helps covered entities manage the complex data, compliance, and financial tracking involved in the 340B program. They serve as the technology and reporting backbone between the covered entity, the pharmacy, and sometimes the wholesaler or manufacturer. A TPA is only as powerful as the structure you build around it.

What Does a TPA Do in 340B?

Here are the main roles a TPA typically performs:

1. Eligibility Matching
   
   • TPAs match prescriptions to eligible 340B encounters using data from your EHR, pharmacy system, and sometimes billing systems. They ensure the patient, provider, and site meet 340B requirements.
2. Inventory Management
   
   • Many TPAs use virtual inventory to track 340B vs non-340B eligible drugs in a contract pharmacy setting, without requiring separate physical stock.
3. Claims Filtering & Accumulation
   
   • They identify and track eligible 340B claims, “accumulate” them until the quantity is sufficient for purchase, and flag them for replenishment.
4. Replenishment Coordination
   
   • TPAs help automate the drug replenishment process between the pharmacy and the wholesaler based on 340B-eligible claims.
5. Reporting & Audit Readiness
   
   • TPAs generate reports used for internal reconciliation, HRSA audits, Medicaid duplicate discount avoidance, and manufacturer data requests (e.g. 340B ESP).
6. Contract Pharmacy Integration
   
   • TPAs sit between the covered entity and the contract pharmacy, facilitating data flow and ensuring compliance with 340B rules.
7. Manufacturer Restrictions Capabilities
   
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A TPA is a powerful tool, but only if it’s set up and managed the right way. It’s not a plug-and-play solution. The value you get depends entirely on how well your data, workflows, and team are aligned behind it. If your referral documentation is inconsistent, your policies aren’t reflected in the system, or no one’s monitoring the setup, you’re likely missing savings or opening yourself up to risk. At the end of the day, a TPA can support your 340B program, but it can’t run it for you. It’s only as strong as the foundation you build around it.

That’s why many organizations work with consulting partners like RxTrail to validate that the TPA’s setup, logic, and data workflows are aligned with actual 340B policy and practice.

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