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The 340B Program Blog

For in depth discussion and information on the 340B Program and to sign-up for our free 340B Primer eBook, see the 340B Program Blog here.

Contract Pharmacy eBook

Click Here to learn about our eBook on Everything you need to know about Contract Pharmacy, plus a sample contract pharmacy agreement for you to use.

Drug Track IQ

Click Here to learn more about how we can help Covered Entities create and manage Track & Trace requirements  that can be challenging for pharmacies.

Contract Pharmacy Analysis

We provide a full compliance check for existing contract pharmacy set-ups.  We also provide guidance and support on setting up your process. Click Here to learn more.

Policies, Procedures, and Audit Guides

Get your policy and procedure documents ready and get your staff educated on them.  Click Here for details on our 340B Policies, Procedures, and Audit Guides.

Audits and HRSA 340B Audit Support

Get HRSA, Independent external audit ready.  Click Here for details on our onsite 340B Auditing services.

Check Out Our Blog


340B, the ACA, and YOU

To fully address the topic of how 340B and the ACA are intertwined would take far more than one blarticle (Roxie word for blog + article); but I will do my best to “nutshell” it. Regardless of your political views and where you stand on the “Repeal and Replace” agenda regarding the Affordable Care Act,

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Contract Pharmacy – Is it a Risk You Are Willing To Take?

When you think of compliance pitfalls in the 340B Program, contract pharmacy immediately comes to mind. Contract pharmacy is one of the highest compliance risk areas of the 340B program; however, the reward of better serving our vulnerable and underserved patients to many is well worth the risk. Contract pharmacies have allowed covered entities to

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Health care reform concept with a RX pharmacy medical symbol in a puzzle jigsaw texture with peices missing as change to the status quo of the broken hospital care insurance and healthcare system that needs to be fixed.

A Review of Expectations to Prevent Duplicate Discount

Carve-In Medicaid Entities: At a minimum, list the NPI of the entity for each registered site on the HRSA database and subsequently the Medicaid exclusion file (MEF).  Covered entities (CEs) with multiple child sites will need to confirm the NPI number used for billing at each site as it might be different than the parent

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340B conference

340B Update: Omnibus Withdrawal & 340B Coalition Conference

Well, big news out yesterday. As of 1/30/2017, the 340B Omnibus Guidance is officially withdrawn. Where does that leave us? Well, that brings be to my second topic, the 340B Winter Coalition Conference. I am in my seat on our airplane to San Francisco. I am excited for this conference, as the legislative sessions will

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Are you ready for a mock audit with Turnkey?

For those who have had an audit from Turnkey, you already know how important it is to have a strategy in place for every drug in every location that ensures 340B compliance. At the very least, this should include ensuring that patient-specific and drug-specific auditable records are maintained and available, that 340B drugs are only

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Split billing company, suggestion on Medicaid Claims for Contract Pharmacy? Consider this

When your split billing company suggests it is Ok to include Managed Care Medicaid claims for contract pharmacy, please consider the following: Allowing managed (MCO) Medicaid 340B accumulations, for contract pharmacy, is not worth the risk because at the end of the day it would likely be the covered entity that would have to work

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What Clients Say

  The Turnkey team of Rich and Rich clearly have extensive hospital experience with 340B and were able to quickly understand our operational issues and provide clear recommendations.  When our team had questions months later they promptly responded to each request with thoughtful and specific advice.


Catawba Valley Medical Center

( Steve Hamm, Pharmacy Manager )

We have contracted Turnkey Rx Solutions for almost a year now. We're very impressed with the work they have been able to provide us. They understand the high standards that our health system has and have been the efficient delivering. I highly recommend working with them.


Florida Hospital

( Alexsandra Rosello, MHA 340B Business Manager )

Turnkey Solutions was well prepared for our mock audit and knew just what questions to ask and where to look for improvement opportunities.  They easily found the needles in the haystack and took the time to understand our practice to make the best suggestions for improvement. ... It was a delight to work with them and I will contract with them again in the future.

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Maine General Medical Center

( Andrea Gimpel-Blanchard, PharmD Director of Pharmacy )

We have been extremely satisfied with the assistance Turnkey Pharmacy Solutions has provided to us as our 340B program has expanded.  We have worked with Rich and Rob and find them to be extremely knowledgeable, thorough, and personable.  Their mission was to identify and minimize any potential risk areas within our 340B program.  As a result, we feel very confident in our processes.

Hellroaring Creek in the Centennial

Southwest Montana Community Health Center

( Tammy A. Cox, PharmD Director of Pharmacy Services )

TurnKey is very knowledgeable of the 340B Program. They identified potential risk areas for our organization and provided us with the necessary corrective action. Thanks to TurnKey, we identified and addressed those risk areas and are now better prepared for a HRSA Audit. 

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Ohio Valley Medical Center 

( Kassie Supanik 340B Pharmacy Coordinator )

The information and resources that were provided through the audit process with Turnkey have been invaluable. We will definitely continue to work with them in the future to ensure our program compliance.


Grand Itasca Clinic & Hospital

( Melissa Walters, PharmD Director of Pharmacy )

Meet Our Team


Rob Nahoopii


Rich Iverson

Project Management

Rich Bucher

Lead Auditor, Legal and Compliance

Annie Nielsen

Lead Pharmacist

Chelsea Campbell

Director of Operations

Roxie Nevarez

Compliance Auditor
Bio PIC2

Megan Kussay

Lead Pharmacist- Auditor

Jennifer Hagen

Lead Pharmacist-Auditor

Jenifer Cook

Compliance Auditor

Some Of Our Partners

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Together, we can get your 340B Program HRSA compliant!

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