Contractor shall provide 340B External Audit Services through the performance of an annual, Health Resources and Services Administration (HRSA)-level audit of CCHCD’s 340B Program to include reviewing the following components: • Assess all program policies and procedures for compliance • Make recommendations on policy/procedure improvements to strengthen programmatic compliance, if necessary • Review compliance with patient definition, to include provider eligibility and adherence to policies regarding frequency of clinic visits • Review pharmacy and 340B Third Party Administrator records to ensure compliance with drug diversion and duplicate discount prohibitions • Comparison of claims data to invoice data • Conduct onsite audit of in-clinic 340B inventory and administrations/dispensations to ensure compliance with diversion and duplicate discount prohibitions • Completion of a randomized audit of 10 in-clinic 340B medications to review for diversion and patient eligibility • Review of all in-clinic 340B inventories for comparison to their respective logged amounts • Review of CCHCD encounter data with a comparison to pharmacy claims data and completion of a randomized audit to review for compliance with diversion and duplicate discount prohibitions • Compellation and submission of a final audit report to County within two weeks of audit completion
