340B Contract Pharmacy & TPA Arrangements (In-Person)

Washington, DC US
September 27, 2023 to September 28, 2023

Please Note: This training is limited to covered entities. If you are not a covered entity and would like to register for this training, please contact us.

Federally Qualified Health Centers (FQHCs), Ryan White HIV/AIDS Program grantees, and other “covered entities” participating in the 340B drug pricing program often rely on contract pharmacies and 340B administrators (sometimes called third-party administrators, or “TPAs”) to carry out their mission, deliver discounted drugs to their patients, and ensure compliance with 340B program requirements. These relationships can be efficient and rewarding when properly understood, monitored, and structured, but missteps can be disastrous.

The majority of 340B program audit findings issued by the Health Resources and Services Administration (HRSA) and its Office of Pharmacy Affairs (OPA) for diversion and duplicate discounts involve contract pharmacies. The findings almost always are the result of the covered entity not fully understanding how its contract pharmacy and/or 340B administrator applies program rules. Covered entities can be surprised to learn that they are solely responsible to the government for compliance and that many contracts proposed by contract pharmacies and 340B administrators leave them with little or no recourse against the vendor.

This two-day intensive training is offered as a comprehensive dive into 340B program contract pharmacy and 340B administrator arrangements. Attendance is limited to a small group of covered entity representatives. Our attorneys will cover these topics and more:

  • Mastering the mechanics of preventing diversion and duplicate discounts, including possible blind spots and pitfalls;
  • Getting the most out of your contracts with contract pharmacies and 340B administrator arrangements, including the protections you need;
  • Understanding the various ways in which covered entities compensate contract pharmacies and TPAs, including compliance concerns with some approaches;
  • Developing sliding fee discount scales that comply with HRSA requirements;
  • Protecting yourself against discriminatory reimbursement contracts;
  • Discussing real-world examples of agreements and disputes using FTLF’s decades of combined experience representing 340B program covered entities; and
  • Implementing best practices and policies and procedures to prevent missteps

Target Audience

  • 340B Covered Entity Executive Staff
  • Financial Leadership
  • Pharmacy/340B Staff
  • Legal/Compliance Teams

*Please Note: This training is limited to covered entities. If you are not a covered entity and would like to register for this training, please contact us

Learning Objectives

After this training, you will be able to:

  • Identify contract terms that put the covered entity at compliance or financial risk
  • Understand the mechanisms used by contract pharmacies and TPAs to identify eligible 340B claims, ensure that payers and Medicaid are billed correctly, and manage 340B program inventory
  • Review and improve existing policies and procedures to reduce 340B audit risks
Course summary
Available credit: 
  • 9.75 Certificate of Attendance
Course opens: 
Course expires: 
Event starts: 
09/27/2023 - 10:00am EDT
Event ends: 
09/28/2023 - 5:00pm EDT


Washington, DC
Wednesday, September 27 - Thursday, September 28, 2023
*Agenda times are all ET and subject to change*


Day 1

Wednesday, September 27, 2023
10:00 a.m. - 5:00 p.m. ET
10:00 - 10:15 a.m.Introductions and Icebreaker
10:15 - 11:30 a.m.
Diversion and Duplicate Discounts
  • How and when do they happen?
  • How do the risks change for Medicaid fee-for-service versus managed care?
11:30 a.m. - 11:45 a.m.Break
11:45 a.m. - 1:00 p.m.
340B and Medicaid Reimbursement
  • How does the Covered Outpatient Drug rule impact 340B?
  • What are states doing to implement the Covered Outpatient Drug Rule?
1:00 - 2:00 p.m.Lunch
2:00 - 2:45 p.m.
Contract Pharmacy Basics
  • What are key contract terms?
  • How will the contract pharmacy operations occur?
  • How will eligibility of claims be determined and communicated?
  • What are the financial terms of the arrangement?
2:45 - 3:00 p.m.Break
3:00 - 3:45 p.m.
Danger Zones: Monitoring and Oversight of Vendors
  • What is required for monitoring and oversight of contract pharmacies?
  • What are best practices?
  • What is an “annual independent audit” and do we really need one?
3:45 - 4:30 p.m.Current State of Contract Pharmacy
4:30 - 5:00 p.m.Wrap-Up Day 1

Day 2

Thursday, September 28, 2023
10:00 a.m. - 4:00 p.m. ET
10:00 - 11:15 a.m.
Case Studies on Day 1 Material
Contracting with TPAs
Fee Structures
340B Inventory Management (Over/Underreplenishment)
11:15 a.m. - 11:45 a.m.

11:45 a.m. - 1:00 p.m.

What Can Go Wrong?
  • Material Breach and Self-Disclosure
  • Vendor Disputes
1:00 - 2:00 p.m.
2:00 - 2:45 p.m.

Audits - OPA and Manufacturer

Non-Audit Inquiries

2:45 - 3:00 p.m.
3:00 - 3:45 p.m.Case Study on Day 2 Material
3:45 - 4:00 p.m.Training Wrap-Up
FTLF Training Center
1129 20th Street NW
Suite 300
Washington, DC 20036
United States
+1 (855) 200-3822
Feldesman Training Room


AC Hotel by Marriott (0.1 mi)
1112 19th St NW
Washington, D.C. 20036

St. Gregory Hotel Dupont Circle** (0.2 mi)
2033 M St NW
Washington, D.C. 20036

Hyatt Place Washington DC/Georgetown/West End** (0.3 mi)
FTLF Discounted Rate Group Code 89073
2121 M St NW
Washington, D.C. 20037

Hilton Garden Inn Washington DC/Georgetown Area** (0.3 mi)
2201 M St NW
Washington, DC 20037

West End Washington DC, Tapestry Collection by Hilton (0.3 mi)
1121 New Hampshire Ave NW
Washington, D.C. 20037

Washington Marriott Georgetown (0.4 mi)
1221 22nd St NW
Washington, D.C. 20037

Embassy Suites by Hilton Washington DC Georgetown (0.4 mi)
1250 22nd St NW
Washington, D.C. 20037

** Discounted Rate available through FTLF link


Michael Glomb

A Partner with the firm, Mike practices in the Federal Grants and Health Care groups, and has over three decades of experience advising community-based organizations on a broad range of legal matters. Specifically, he offers guidance to Federally Qualified Health Centers, other federal grantees, and several professional and trade associations on the 340B drug discount program, tax exemption, grants law, and fraud matters. [Full Bio]

Katie Watson

Katie Watson is the General Counsel and Chief Compliance Officer of Whitman-Walker, a Washington-DC based safety net provider which participates in the 340B program.  Prior to assuming this role, Katie served as Senior Counsel to Maxor National Pharmacy Services (an independent pharmacy company that manages pharmacies on behalf of 340B covered entities as well as operates a 340B third-party administrator) and as in-house counsel with MedStar Health, where she was the attorney responsible for 340B contracts and compliance across the healthcare system.  Katie’s law practice also has been understanding health systems and federally qualified health centers while Senior Associate at Feldesman Tucker Leifer and Fidell, LLP. She holds a bachelor of arts from Brown University, a masters in public health from Johns Hopkins Bloomberg School of Health, a law degree from Georgetown University, and an LLM in business and health law from Loyola University Chicago.   

Participants can earn up to 11.60 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.


  • Prerequisites: None 
  • Target Audience: 340B Covered Entity Executive Staff, Financial Leadership, Pharmacy/340B Staff, Legal/Compliance Teams
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group-Live

Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).

Available Credit

  • 9.75 Certificate of Attendance


Please login or register to take this course.


This training will not be recorded for later viewing, as we would like attendees to be comfortable and candid, sharing their experiences and asking scenario-based questions. The discourse between the attorneys and participants is a valued part of each training.



Group Discounts

Bring your team! Discounts are available for groups of three (3) or more individuals from the same organization. Please contact us to process your registration.

Groups of 3 - 6
Groups of 7 - 10
Groups of 11 - 15
Over 15 attendees
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Registration Instructions

Each registration must be in the name of the individual(s) who will attend. This allows FTLF to communicate important course information to the actual attendee(s), add training materials and handouts to the right account, and properly assign certificates of attendance or CPE credits. 

To register for this training:

  • For yourself: login to your account and register with your personal information
  • For someone else: login with the ATTENDEE’S login information or create an account for the ATTENDEE and register from the ATTENDEE's account
  • For a group: email Learning@ftlf.com to complete group registration

If you encounter problems or have questions Contact us.


We accept payment by PayPal, credit card, and check. Payment for any live training is due upon registration. If payment is not received in full prior to the start of the event, FTLF reserves the right to cancel your order and deny you entrance to the training.

Cancellation/Transfer Policy

All cancellation or transfer requests must be received in writing at learning@ftlf.com. Requests for refunds or transfers for in-person events will be granted according to the following schedule:

  • 45 or more days prior to the event, requests for a full refund or a transfer, minus a $75 administrative fee, will be granted.
  • Between 15 to 44 days prior to the event, requests for cancellations will be granted, subject to an administrative fee equal to 50% of the paid registration fee. Requests for transfers may be granted, space permitting and subject to a transfer fee.
  • Within 14 days of the event start date, no requests for refunds or credits will be granted. At FTLF's discretion, late transfers may be granted, space permitting and subject to a transfer fee.

Cancellation of a registration with group pricing may result in the discount being revoked or reduced for the entire group.

If there are extenuating circumstances regarding your cancellation, please reach out to the FTLF Training Team directly at learning@ftlf.com.

Can I transfer from in-person to the virtual classroom? 

Yes, you can transfer from attending in-person to virtually.  Please note that no refunds of the price difference, if any, will be given.  Within 45 days of the event start date, transfers from in-person to virtually will be subject to a transfer fee. Within 14 days of the event start date, no transfers from in-person to virtual will be permitted. All transfer requests must be submitted in writing.  

If there are extenuating circumstances regarding your cancellation, please reach out to the FTLF Training Team directly at learning@ftlf.com.