Clear 340B Referral Program Policies That Protect Patient Referrals at Your FQHC

Yes, referral prescriptions are allowed under 340B rules if the covered entity maintains current and ongoing responsibility for the patient's care. The key is establishing clear documentation that demonstrates this ongoing relationship. We help you define when this policy applies and how to substantiate it with proper documentation that satisfies HRSA requirements. Your compliance program must clearly outline when a physician maintains the necessary relationship for 340B eligibility.

We consider HRSA audit experience, financial impact analysis, and your organizational risk tolerance to help you develop a compliance-forward but financially strategic policy. Our approach examines your patient data, claims data, and referrals made to establish parameters that protect your organization while maximizing appropriate 340B savings. We analyze spending and patient volume patterns to create thresholds that work for your specific medical center or community health organization.

Yes. We ensure your referral eligibility policy can be uniformly applied across all TPAs, EMRs, and operational processes to ensure consistency and defensibility. Implementation includes configuring your referral platform settings, updating referral forms, and training staff on how to make a referral that maintains 340B compliance. We help standardize the process so every successful referral follows the same documented procedures.

FQHC organizations have unique referral capture requirements due to their community health mission and patient population. We develop policies that recognize the special considerations for federally qualified health centers, including how to document ongoing patient care relationships and maintain compliance when providers make a referral to specialists. Your policy must address both national and state requirements while supporting your mission to provide access to underserved populations.

When staff make a referral, proper documentation must demonstrate ongoing responsibility for patient care. This includes maintaining patient data that shows continued involvement in treatment planning, follow-up care, and care coordination. We help you create referral forms and processes that capture the necessary information to support 340B eligibility. Your pharmacist and clinical staff receive clear guidance on documentation requirements for each referral made.

Policy change implementation requires careful coordination across all locations to ensure uniform application. We develop implementation plans that address each medical center's specific workflows while maintaining consistency. This includes updating referral workflow materials, training staff on new procedures, and ensuring your referral platform reflects the updated policies.

When you receive referrals that don't meet 340B eligibility criteria, having clear policies helps staff make appropriate decisions quickly. We help you establish screening procedures that identify eligible referrals while maintaining quality patient care. Your team learns to use a referral process that maximizes appropriate 340B capture while ensuring compliance. This is one of the best ways to protect your program while serving patients effectively.

Yes, we help you establish referral metrics that measure both compliance and program effectiveness. This includes tracking direct referrals, monitoring referral patterns, and analyzing patient access improvements. We can assist with setting up tracking systems using UTM parameters and other tools to measure referral program performance. Your ability to demonstrate program success depends on having clear metrics that show both compliance and patient care benefits per patient served.