Since 2019, VytlOne has supported the 340B programs of more than 100 health systems and health centers. We’ve published dozens of posts exploring 340B topics and trends — major, minor and developing. Recently, we were asked by a reader to produce a post offering our thoughts on, and predictions for, the program’s future. 

If there is any one word we believe, with 100% certainty, that will characterize the future of 340B, it’s Data — while the word we believe will become increasingly-central to its future is Transparency. That said, below are the key developments we foresee for 340B, moving forward:

1. Increased granularity and timeliness of 340B data

• As more health systems adopt advanced analytics and data-mining, the demand will grow for more frequent, and more granular data on 340B-eligible prescriptions, fills, contract pharmacy flows, formulary exclusions, manufacturer restrictions and revenue reinvestment.
• Toward that end, forward-thinking 340B health systems will utilize real-time monitoring of key metrics, including: The number of 340B-eligible prescriptions, capture rate (eligible vs captured), margin per fill, revenue reinvested, and patient outcomes (readmissions, adherence).
• Transparency of data will increasingly mean dashboards for leadership, board reporting, even public benchmarking (particularly if, as expected, increased regulatory and industry pressure continues). Health systems will want to show how their 340B revenue is deployed back into 340B’s core mission of supporting increased healthcare access to underserved patient populations.

2. Enhanced transparency for 340B stakeholders 

• With higher quality data available, it’s likely that stakeholders (including community advocacy groups, oversight bodies and manufacturers) will demand greater transparency about how 340B savings are used — and not just how much is saved, but how it’s re-invested in patient care, particularly healthcare access for underserved populations. 
• Health systems might consider proactively publishing “340B impact reports” showing the number of additional patients they’ve served with their 340B revenues, as well as ne clinics opened, readmission rates improved — all linking 340B savings to outcomes. This kind of linkage bolsters the narrative that 340B is about community health, not just revenue.
• Manufacturers and payers may push for more visibility into contract pharmacy networks and flows, challenging diversion or duplicate discounts. As data becomes more transparent, oversight of contract pharmacy arrangements will intensify.
• HRSA may lean toward requiring more frequent, standardized reporting — and, possibly, public disclosure of key program metrics (especially given ongoing policy debates about 340B scope and fairness).

4. Use of advanced 340B software analytics

• Although AI has advanced, many errors still require manual review — especially around data mismatches and eligibility. Going forward:
  • Systems will blend AI and automation (for flagging mismatches, anomalies in claims flows, contract pharmacy networks) with human review for edge-cases, complex manufacturer restrictions and policy shifts — among others.
  • Predictive analytics will emerge, such as: Predicting which prescriptions are likely 340B-eligible but not captured. Forecasting revenue leakage. Modeling scenarios under changes in everything from manufacturer policies and regulations to contract pharmacy networks.
  • Analytics will also help tie 340B program performance to clinical / outcome metrics. Health systems will be better equipped to correlate increased 340B capture with lower readmissions, better adherence and improved health outcomes in the underserved populations they support. 

5. Regulatory shifts enabled by 340B data transparency

• With more and better data, regulators will be better positioned to evaluate health systems’ program performance, and assess whether the 340B program’s goals of serving underserved patients and stretching federal resources are being met.
• Standardization and transparency may lead to policy refinements, such as: Requiring contract pharmacies to report on counts of 340B fills. Requiring health systems to publicly report how 340B savings are being used. Or even tying program discount rates to demonstrable reinvestment metrics. In short, 340B reimbursement may become tiered — rewarding better-performing health systems with higher rates of 340B savings.
• At the same time, health systems will likely face greater scrutiny and auditing pressure — even performance benchmarking against peers.
• In light of more transparent data, it’s a virtual certainty that manufacturers will seek to negotiate 340B reimbursement to their own overall advantage. Health systems will need to be prepared.

6. Strategic implications for 340B health systems 

Given all of the above, health systems should be proactively preparing:

• Governance and accountability: Establish internal governance structures responsible for 340B oversight, data integrity and reporting to leadership and boards. Extend beyond pharmacy to include analytics, compliance, patient access, community impact.
• Data architecture: Invest in data infrastructure/tools that can: Ingest EHR, TPA, dispensing and contract pharmacy data. Support standardized 340B data models. Handle the complexities of working with multiple EHRs, TPAs and 340B data mismatches. 
• Metrics & transparency plan: Define Internal Key Performance Indicators around 340B, including: Capture rate. Margin per 340B-eligible fill. Number of 340B patients reached (especially underserved / indigent patients). Readmission rate improvement attributable to 340B revenues and integrated program management. Pharmacy margins. Contract pharmacy network growth. Reinvestment in community services with 340B revenue. All of which is why 340B health systems should prepare for reporting they can publish and share externally.
• Risk management: Recognize that with greater transparency comes greater risk — including increased public scrutiny and audits. Which is why 340B entities should re-double efforts to ensure program oversight and compliance, including: Accurate documentation. Audit trails. Standardized processes for contract pharmacy management. Manufacturer restrictions. Eligibility documentation.
• Strategic alignment with 340B’s mission: As we pointed-out in our post, How To Use Your 340B Program As a Community Health Engine, health systems that align their 340B programs with the mission of expanding services, and creating better access for all patients, will be better positioned to tell their story — and justify the very real benefits their programs deliver beyond mere cost-savings. 
• Patient experience & outcomes linkage: As we pointed-out in our post, The Holistic Pharmacy Approach To 340B Patient Support, the most effective 340B programs use Pharmacy as an integral part of their care model — which includes: On-site retail and specialty pharmacies. Pharmacist-physician collaboration. Meds-to-Beds and Readmission Reduction. 
• Contract pharmacy network optimization: We’ve said it many times in the past: We have never served or encountered a 340B health system whose contract pharmacy network we couldn’t improve — both in quality and quantity. That said, we believe reporting on contract pharmacy flows will become increasingly critical to establishing transparency expectations.

Key 340B uncertainties & strategic questions

While the direction is clear, several uncertainties remain that health systems and stakeholders should monitor:

• What will regulators mandate? Will HRSA or CMS require standardized public reporting of 340B metrics? If so, when and in what format? How will the industry respond?
• How will manufacturers react? As data transparency improves, will manufacturers push tighter restrictions, more documentation, greater oversight of contract pharmacy networks? (YES) Will this reduce eligible fills or increase administrative burden? (BOTH)
• What level of benchmarking will emerge? If health systems start publishing their 340B data, will peer benchmarking among 340B health systems become common? Will be “good / bad” comparisons among those health systems become public information?
• How will 340B technology evolve? How soon, if ever, will AI consistently solve the many 340B Data Mismatch issues mentioned in our post Optimize 340B Program Savings & Compliance With Data Mining? Or will human oversight and insight remain necessary — at least for the complex cases? As we pointed-out in the post, AI is not a consistently reliable solution yet. 
• How will 340B “reinvestment” be defined and verified? Increasing transparency means more 340B health systems will be expected to answer the question, “How are you using the savings from your 340B program?” Further scrutiny regarding what counts as reinvestment is likely. Will this give rise to standardized categories (indigent care, community clinics, readmission reduction) and auditing?
• Will the patient-impact narrative become more central? As health systems emphasize 340B’s role in improving patient access and outcomes — as well as overall support of their mission in the communities — will the data generated support those claims? Will outcomes be formally tied to 340B’s impact in published reports or audits?

340B program recommendations, moving forward

Here are some actionable recommendations for 340B health systems and program administrators who want to stay ahead of the proverbial curve:

1. Build a better 340B-dashboard now

At the very least, your 340B software should have a dashboard that delivers instant access to the following: Eligible fills. Captured fills. Capture rate. Margin per fill. Contract pharmacy counts and volumes. Reinvestment uses. Patient outcome indicators. And, critically, actionable trends in every data category.

2. Standardize 340B data ingestion & cleaning

Health systems’ 340B program managers should: Work with their IT and pharmacy operations to standardize patient identifiers (particularly the simple ones, like patient date of birth and name). Align EHR and dispensing systems. Manage TPA portal data feeds. Reduce mismatches that lead to missed opportunities.

3. Define and publish your 340B “story”

Consider creating an annual 340B Impact Report you can promote publicly. One that includes: How many patients have been served. New services enabled by 340B revenue. Pharmacy access metrics. Measurable improvements in readmission. This report should also be used for internal communications, board reports and stakeholder engagement.

4. 340B governance & compliance structure

Set up a cross-functional 340B governance committee (one incorporating pharmacy, finance, compliance, IT and community health) to oversee your health systems’ overall 340B program, as well as: Data transparency. Contract pharmacy strategy. Management of manufacturer restrictions.

5. Prepare for external scrutiny of your 340B program

Given the trajectory toward greater transparency, your health system should prepare for audits, benchmarking and public disclosures. Which is why you should 1) Document your policies for contract pharmacies, data flows, manufacturer limitation tracking and patient eligibility workflows, and 2) Educate everyone connected to your 340B program, from program managers and support staff to pharmacists and healthcare providers.

6. Leverage your 340B analytics proactively

There is no question your 340B program is operating less than optimally if you aren’t already using data mining to identify opportunities in every corner, including: Missed captures. Potential contract pharmacy expansion. Formulary insights. Patient medication adherence patterns. Again, you should combine your technology with human oversight, as perfection by AI alone is not yet achievable.

7. Link to 340B outcomes

Strengthen the clear linkage between your 340B program operations and actual patient outcomes (access, adherence, readmissions, etc.). Be able to document the most fundamental connections, IE: “Because we captured X% more 340B eligible fills, we reinvested Y dollars and thereby expanded Z services, resulting in A% reduced readmission for certain populations.” This focus on patient outcomes will support your “healthcare mission” narrative, and help you defend your 340B program when it’s subjected to scrutiny.

Final Thoughts

The 340B landscape is moving steadily toward greater data-driven sophistication, standardization of reporting, and program transparency — both internally within health systems and externally to stakeholders. 

For health systems, the imperative is clear: Don’t treat 340B as just a discount program; treat it as a strategic asset integral to improved and expanded care delivery, with robust data capabilities, governance and transparency. 340B health systems who build the necessary data infrastructure and reporting discipline now will be better prepared for future regulatory demands, benchmarking, stakeholder expectations, and — more importantly — for delivering meaningful patient care and community impact.

VytlOne is here to help.

To learn how VytlOne can help your health system succeed in an ever-changing 340B environment, contact Howard Hall. howard.hall@VytlOne.com | 214.808.2700