Termination Date (OPAIS)
Definition
OPAIS records a termination date when a covered entity or registered site is removed from the 340B program. From the termination date forward, the entity or site is no longer eligible to participate in 340B purchasing, dispensing, or billing activities. Termination dates are updated quarterly.
Termination can result from a covered entity’s voluntary withdrawal, failure to complete annual recertification, loss of eligibility (such as a DSH percentage falling below the required threshold), or HRSA enforcement action. Once terminated, the entity must immediately stop purchasing, using, and administering 340B drugs.
Continuing to purchase or dispense 340B drugs after a termination date is a serious compliance violation. Covered entities with multiple sites must monitor the eligibility status of each site to ensure no terminated locations continue operating under 340B.
Frequently Asked Questions
Why Termination Date (OPAIS) Matters
Continuing 340B activity after a termination date is a significant compliance violation. Covered entities must have processes to monitor the eligibility status of all registered sites and immediately cease 340B purchasing when a site is terminated.
How Virtue 340B Uses It
Virtue 340B monitors OPAIS data for all registered sites as part of our continuous monitoring service, flagging any termination events or eligibility changes that require immediate operational response.