2.1.1. Phase I: Data Review: 2.1.1.1. Review of any medicare/medicaid or private billing decisions; 2.1.1.2. Review eligible prescription volume. 2.1.2. Phase II: Verification of Program Eligibility and Review of Operational Procedures: 2.1.2.1. Eligibility and registration review, including detailed review of the Office of Pharmacy Affairs Information System (OPAIS); 2.1.2.2. Review of Memorandum of Understanding (MOU)/grant; 2.1.2.3. Review of 340B policies and procedures; 2.1.2.4. Review of contract pharmacy’s policies and operations relationships including active pharmacy services agreements (PSAs); and 2.1.2.5. 340B purchasing account review to include purchase order and inventory management. 2.1.3. Phase III: Health Resources and Services Administration (HRSA)-Style Random Sampling Audit 2.1.3.1. Ten (10) records for prescriptions data universe per 340B ID; and 2.1.3.2. Review 340B medications through entire accumulation to purchasing process (tracer samples) 2.1.4. Phase IIII: Provide comprehensive report complete with detailed findings annually: 2.1.4.1. Recommendations, and next steps. The report will include all eleven (11) 340B IDs; and 2.1.4.2. A call or in-person meeting will be scheduled to review the report in detail with staff.
