Virtue 340B

09/28/2026

HRSA audit readiness is easier to manage when your team already knows where the data is, who owns each step, and how the process should work.

In this episode of Katy’s 340B Compass, Katy Lees walks through practical ways to prepare for a HRSA audit, including practicing the data pull, reviewing policies and procedures, organizing documentation, validating information before submission, and protecting PHI and sensitive data.

She also shares an important reminder for audit conversations: answer the questions clearly, explain your process, and stay focused on what is being asked.

Visit Virtue 340B’s website to watch or listen to the episode on your preferred platform. https://virtue340b.com/content-hub/katys-340b-compass/

Watch Katy Lees, 340B ACE-certified advisor, break down complex compliance topics with practical guidance you can apply to your program today.

09/02/2026

340B growth is often discussed in simple terms — but the data tells a more complex story.

In this episode of Katy’s 340B Compass, Katy Lees looks at why rising 340B spending should not be separated from rising drug acquisition costs, increasing patient complexity, and broader changes in healthcare delivery.

You’ll hear why price, total spending, utilization, and patient acuity are different measures — and why that distinction matters for honest policy discussions, stronger oversight, and better organizational decision-making.

Visit Virtue 340B’s website to watch or listen to the episode on your preferred platform.
https://virtue340b.com/content-hub/katys-340b-compass/

Watch Katy Lees, 340B ACE-certified advisor, break down complex compliance topics with practical guidance you can apply to your program today.

07/13/2026

340B policy conversations are moving quickly, and covered entities need a clear way to understand what may be ahead.

In this episode of Katy’s 340B Compass, Katy Lees discusses the proposed CMS OPPS reimbursement change from ASP plus 6% to ASP minus 33.4%, and why safety-net hospitals should evaluate the potential financial and operational impact.

Katy also breaks down two different 340B legislative approaches: the SECURE 340B Act and the Integrity/Affordability draft. The episode looks at how each framework approaches contract pharmacy, rebates, patient definition, child sites, transparency, patient affordability, payers, PBMs, and vendor compensation.

This conversation is especially helpful for leaders who need to understand the broader implications for oversight and planning, not just the technical policy details.

Visit Virtue 340B’s website to watch or listen to the episode on your preferred platform.
https://virtue340b.com/content-hub/katys-340b-compass/

Watch Katy Lees, 340B ACE-certified advisor, break down complex compliance topics with practical guidance you can apply to your program today.

07/02/2026

340B data does not always fit neatly into a clean box.

In this episode of Katy’s 340B Compass, Katy Lees talks about a common statement in the manufacturer data-sharing conversation: that the requested data is simply “the same data” covered entities already send to payers.

But in many 340B programs, the pharmacy claim is submitted for adjudication before the 340B determination has been made. Eligibility may be determined later through accumulation, qualification, replenishment, reversals, and other operational processes.

That timing matters.

This episode looks at why covered entities need to understand their own facts, systems, contracts, patient impact, and compliance concerns when evaluating data-sharing decisions. It also recognizes that there are risks on both sides: risks of submitting data and risks of not submitting data.

Visit Virtue 340B’s website to watch or listen to the episode on your preferred platform.
https://virtue340b.com/virtue-340b-content-hub/katys-340b-compass/

Watch Katy Lees, 340B ACE-certified advisor, break down complex compliance topics with practical guidance you can apply to your program today.

06/29/2026

A common question we ask healthcare leaders is:

"𝗛𝗼𝘄 𝗱𝗼 𝘆𝗼𝘂 𝗸𝗻𝗼𝘄 𝘆𝗼𝘂𝗿 𝟯𝟰𝟬𝗕 𝗽𝗿𝗼𝗴𝗿𝗮𝗺 𝗹𝗼𝗼𝗸𝘀 𝘁𝗵𝗲 𝘀𝗮𝗺𝗲 𝘁𝗼𝗱𝗮𝘆 𝗮𝘀 𝗶𝘁 𝗱𝗶𝗱 𝗮𝗳𝘁𝗲𝗿 𝘆𝗼𝘂𝗿 𝗹𝗮𝘀𝘁 𝗮𝘂𝗱𝗶𝘁?"

For many organizations, the answer is difficult.

Not because controls are absent.

But because programs change constantly.

Providers join and leave.

Locations expand.

Vendors make updates.

Workflows evolve.

And risk can develop quietly between formal reviews.

Independent continuous monitoring helps bridge that gap.

By providing ongoing visibility into key risk areas, organizations can identify issues earlier, strengthen oversight, and maintain confidence that their program remains aligned with internal expectations and regulatory requirements.

At Virtue 340B®, our Continuous Monitoring Program is designed to help healthcare organizations move from reactive compliance to proactive oversight.

Explore the program:
🔗 https://virtue340b.com/340b-continuous-monitoring-program/

Keep your 340B program audit-ready year-round with quarterly compliance reviews, claims analysis, and proactive issue detection across all sites.

06/24/2026

Every 340B professional has them.

The questions that keep coming up in meetings.

The topics that generate debate internally.

The regulations that seem straightforward—until you try to apply them in practice.

At Virtue 340B®, we know that some of the most valuable industry conversations begin with a simple question.

That's why we're inviting healthcare professionals to submit questions for future episodes of 𝗞𝗮𝘁𝘆'𝘀 𝟯𝟰𝟬𝗕 𝗖𝗼𝗺𝗽𝗮𝘀𝘀, our educational podcast and blog series hosted by Principal 340B Compliance Advisor Katy Lees.

Questions can cover topics such as:
✔ Provider eligibility
✔ Contract pharmacy oversight
✔ Audit readiness
✔ Duplicate discount prevention
✔ Manufacturer restrictions
✔ Program governance
✔ Emerging regulatory developments

Questions submitted will not be publicly attributed to your organization. Instead, Katy will address selected topics in future episodes to help the broader 340B community navigate common challenges and areas of uncertainty.

If there's a question your team has been discussing, there's a good chance others are asking it too.

Submit your question here:
🔗 https://virtue340b.com/content-hub/katys-340b-compass/

The best conversations often start with the questions we're willing to ask.

Watch Katy Lees, 340B ACE-certified advisor, break down complex compliance topics with practical guidance you can apply to your program today.

06/16/2026

Discussions about 340B program growth often focus on a single metric: total 340B purchases.

But what if that number only tells part of the story?

As conversations around the future of the 340B Program continue, it's worth asking a broader question:

What factors are actually contributing to the growth we're seeing?

Healthcare inflation. Specialty drug utilization. Expansion of outpatient care. Hospital consolidation. Growing patient demand for complex therapies.

These trends are reshaping healthcare delivery nationwide, yet they're often missing from discussions about 340B growth.

In our latest article, we explore several important considerations that provide additional context for understanding the data and why simple narratives may overlook the realities facing hospitals and health systems today.

If you're involved in 340B oversight, compliance, pharmacy leadership, or healthcare finance, this discussion is worth following.

Read the full article here:
🔗 https://virtue340b.com/340b-growth-in-context-what-the-data-shows/

Learn the key factors behind 340B program growth and what the data actually reveals.

06/11/2026

If your organization were asked today to explain how it oversees its 340B program, could leadership clearly answer the question?

Not just whether the program is compliant.

But where risk exists.

What controls are in place.

How oversight decisions are documented.

And whether those decisions would remain defensible months—or years—from now.

These are the questions independent audits are designed to answer.

The strongest 340B programs aren't necessarily the ones with the fewest findings.

They're the ones that understand their risks, maintain visibility into their operations, and continuously strengthen oversight.

At Virtue 340B®, our independent audits help healthcare organizations move beyond compliance checklists and gain meaningful insight into program risk, governance, and operational durability.

Explore our Independent 340B Audit Services:
🔗 https://virtue340b.com/independent-340b-audits/

Prepare for HRSA oversight with a comprehensive independent 340B audit. Identify compliance gaps, strengthen policies, and protect your program.

06/01/2026

Final reminder — our upcoming webinar with 𝗛𝗔𝗡𝗬𝗦 𝗠𝗮𝗿𝗸𝗲𝘁𝗽𝗹𝗮𝗰𝗲 is just 48 hours away!

As 340B complexity continues to increase, many organizations are asking the same questions:

Do we have clear visibility into how our program is operating?
Are our eligibility and documentation approaches truly defensible?
Where could risk be quietly accumulating?

Join 𝗩𝗶𝗿𝘁𝘂𝗲 𝟯𝟰𝟬𝗕 on 𝗪𝗲𝗱𝗻𝗲𝘀𝗱𝗮𝘆, 𝗝𝘂𝗻𝗲 𝟯, at 𝟭𝟮 𝗣𝗠 𝗘𝗧 for:

𝗖𝗼𝗻𝘁𝗿𝗼𝗹𝗹𝗶𝗻𝗴 𝗪𝗵𝗮𝘁 𝗬𝗼𝘂 𝗖𝗮𝗻 𝗶𝗻 𝗮 𝟯𝟰𝟬𝗕 𝗘𝗻𝘃𝗶𝗿𝗼𝗻𝗺𝗲𝗻𝘁: 𝗦𝘁𝗿𝗲𝗻𝗴𝘁𝗵𝗲𝗻𝗶𝗻𝗴 𝗢𝘃𝗲𝗿𝘀𝗶𝗴𝗵𝘁, 𝗩𝗶𝘀𝗶𝗯𝗶𝗹𝗶𝘁𝘆, 𝗮𝗻𝗱 𝗗𝗲𝗳𝗲𝗻𝘀𝗶𝗯𝗶𝗹𝗶𝘁𝘆

We’ll discuss practical approaches to strengthening program oversight, improving visibility into potential exposure areas, and navigating evolving expectations surrounding eligibility, duplicate discounts, and recertification.

If you are involved in 340B oversight, compliance, pharmacy operations, finance, or audit readiness, we’d love to have you join the conversation.

🔗 Registration Link: https://my.hanys.org/Events/Calendar-Of-Events/Meeting-Home-Page?meetingid=%7b7fbc4d11-3538-f111-88b4-6045bd01524d%7d

05/25/2026

Today, we pause to remember and honor the courageous individuals who gave their lives in service to our nation.

Wishing everyone a meaningful and reflective Memorial Day from the Virtue 340B team.