It’s no secret that 340B data accuracy is the sole responsibility of the Covered Entity, but sometimes the “source of truth” for data can be hazy. This is especially true when it comes to child sites and contract pharmacies. You may be attuned to the recent address change of your nearest clinic, and you may have heard your contracted big box pharmacy moved down the street, but when HRSA comes knocking with an audit request, you’ll need more concrete records at your disposal.
HRSA uses the OPAIS database (https://340bopais.hrsa.gov/) as a source of truth for your 340B program. If a contract pharmacy has a change of address, OPAIS will update their database to reflect it. This can cause problems, however, if the OPAIS record doesn’t match your Pharmacy Services Agreement contracts (such as different addresses, zip codes, etc.). Occasionally pharmacy information changes, and you won’t necessarily receive notice about it. In addition, OPAIS won’t automatically update changes to your CE, such as clinic status, address, contact information, or child sites. It can all be a bit of a moving target, so what’s the best way to navigate it?
