The Ultimate 340B Compliance Audit Checklist For Program Managers | Carrie Yannarella cover art

The Ultimate 340B Compliance Audit Checklist For Program Managers | Carrie Yannarella

The Ultimate 340B Compliance Audit Checklist For Program Managers | Carrie Yannarella

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340B audit readiness is the operational ability of a covered entity to maintain explicit, trackable evidence of patient eligibility, pharmacy dispensation, and drug accumulation logic, proving immediate HRSA compliance on any given day.


Are you relying on end-of-year mock audits to save your 340B program from HRSA scrutiny?
This week on *340B Pulse*, host Muhammad Atif stands alongside Salman Asif to explore the realities of operational compliance with Carrie Yannarella. With decades of outpatient clinical operations experience, Carrie breaks down why relying on reactive tracking guarantees an audit failure. Rather than scrambling to find missing referral logs and unmapped Medicaid modifiers hours before an external audit, Carrie teaches program managers how to establish a continuous, frictionless monthly rhythm.
If you are a covered entity executive or a pharmacy leader exhausted by compliance burnout, this episode offers a practical, step-by-step masterclass on how to deploy TPA platforms efficiently, sample the right claims, and force cross-functional accountability without overwhelming your staff.


What You’ll Learn in This Episode

- The definition of true 340B audit readiness and why reactive models fail.

- How to efficiently identify drug diversion through monthly purchasing variance reviews.- The precise methodology required for targeted 10% claim sampling.

- How to structure reporting handoffs between Pharmacy, Clinics, and Finance correctly.- Essential project management strategies for defeating compliance burnout.


[00:00] – Intro to 340B Pulse and NorthArc Health

[04:49] – Understanding the Mindset Behind Daily Audit Readiness

[06:24] – How to Actively Monitor High-Risk Dispensations

[07:48] – The Danger of Random Sampling vs. Targeted Sampling

[10:50] – Breaking Down Departmental Silos for Perfect Traceability

[14:55] – The Crucial Artifacts You Must Keep Ready for HRSA

[16:33] – Preventing Burnout Using Basic Technology Tools

[18:00] – Closing Notes and the Importance of Agentic AI

Q: What exactly is 340B audit readiness?

A: Audit readiness is a proactive operational philosophy ensuring that a covered entity tracks and documents every step of their 340B workflow so perfectly that they could successfully pass an unannounced HRSA compliance audit immediately.


Q: Who is responsible for 340B program compliance?

A: Program compliance is a deeply cross-functional responsibility requiring Pharmacy to control drug builds, Clinics to control referral documentation, and Finance to manage the ultimate auditing and claims retrieval.


Q: Why do covered entities fail HRSA audits?

A: Covered entities typically fail HRSA audits due to systemic drug diversion, meaning they lack the concrete internal clinical systems, like EMR data interoperability, needed to prove they actively maintained medical responsibility for the patients receiving discounted medications.


Brought to you by NorthArc Health. We engineer intelligent Agentic AI software that drives unshakeable administrative visibility. Reach out for a consultation today.

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