Child Site (340B)
Definition
A child site is an offsite outpatient facility of a hospital covered entity that is registered in OPAIS as a separate 340B site. To qualify as a child site, the facility must be listed as a reimbursable facility on the parent hospital’s most recently filed Medicare cost report, with associated outpatient costs and charges.
Child sites receive their own 340B IDs and can participate in 340B drug purchasing independently. All clinics located offsite of the parent hospital—regardless of whether they are in the same building—must register as child sites if they want to participate in 340B.
A free-standing clinic that submits its own cost reports under a different Medicare provider number (not under the covered entity’s Medicare provider number) is NOT eligible to register as a child site. This is a common source of confusion and compliance risk for hospital systems with complex organizational structures.
For FQHCs, the equivalent concept is ‘associated sites’ rather than child sites, reflecting a change in HRSA terminology implemented in September 2017.
Frequently Asked Questions
Why Child Site (340B) Matters
Properly registering child sites is essential for hospital systems that want to extend 340B benefits to their offsite outpatient facilities. Errors in child site registration—including registering ineligible facilities—are a common source of HRSA audit findings.
How Virtue 340B Uses It
Virtue 340B reviews child site eligibility and OPAIS registration accuracy as part of our audit and consulting engagements, ensuring that all registered child sites meet the Medicare cost report requirement and that no ineligible facilities are registered.