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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


 CMS Releases Final OPPS Rates for 340B Covered Entities

On November 1, CMS released their final rule implementing Part B payment reductions for Disproportionate Share Hospitals (DSH) as well as Rural Referral Centers (RRC).  The Final Rule, which will begin January 1st 2018, will reduce payment for most separately reimbursed Part B drugs from a current average sales price (ASP) + 6% to ASP

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indirect referrals

Mitigating Risks of Indirect Referrals

Sometimes, reliance on a referral request to an outside prescriber (e.g., specialist) to qualify a prescription as 340B eligible can be relatively straightforward. For instance, when a direct referral request to the actual prescriber is documented in the patient’s medical record along with a referral visit summary back closing the loop, the covered entity’s responsibility

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Chief Cook and Bottle Washer: Self-Auditing For 340B, When You Are the ‘Whole Enchilada’

Let’s be honest, pharmacy is not for the faint of heart. Add to regular pharmacy duties the immense joy of the 340B program and you can be over your head…quickly. 340B self-auditing can feel like a pipe dream. HRSA auditors may haunt your nightmares, with Zombies, that have an uncanny resemblance to your CFO and

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340B Summer ’17 Coalition Meeting

We had a great time in DC for the 340B Coalition Meeting. Thank you to everyone who stopped by the booth to say hello, or to learn more about our services. We thought the conference did well with keeping the 340B community updated on what is potentially coming with 340B changes, of course, it is

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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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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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