Episode Summary
In this episode of 340B Pulse, Muhammad Atif speaks with Bryan McCormick, Corporate Director of the 340B Program at RWJBarnabas Health. Bryan brings more than 15 years of 340B operations experience across large health systems, with deep work in claims and purchasing oversight, contract pharmacy coordination, auditing, and financial impact analysis.
The core argument is that 340B program performance is increasingly a claims-data problem, not a policy-literacy problem alone. Most covered entities do not operate from a single source of truth. They reconcile fragmented pharmacy claims, medical or split-billing flows, payer logic, PBM and TPA feeds, wholesaler purchasing data, and EHR outputs that were never designed to align cleanly at the patient or claim level. As contract pharmacy networks expand and manufacturer data-sharing requirements multiply, the operational burden shifts from "getting data" to validating, standardizing, and defending what the data says.
Bryan explains why TPA configuration is ultimately a covered-entity compliance decision (including visit-timing rules that are subject to interpretation), why many organizations quietly run three or more TPAs when retail partners mandate their own platforms, and why aggregation is time-consuming even when it is not technically impossible. He contrasts split billing and contract pharmacy as structurally separate operational worlds, stresses garbage-in/garage-out discipline across NPI and location rosters, and describes the EHR as the practical source of truth that must feed every downstream system correctly.
The conversation also covers where breakdowns occur (internal change management, pharmacy switches, connectivity failures), why monitoring volume anomalies matters, what reconciliation failures trigger (root cause, leadership escalation, self-disclosure thresholds), scaling with simplicity (Epic and Verity integration at RWJBarnabas), why dedicated 340B FTEs are non-negotiable at today's complexity, manufacturer portal fragmentation (ESP, Truzo, and others), and a conservative view of AI and additional vendors: helpful eventually, but every new integration is another line to police when compliance still sits with the covered entity.
Bryan closes with practical advice for operators: the plug-and-play era is over, policing inputs and vendor outputs is necessary work, and 340B leaders must insert themselves into enterprise stakeholder rhythms so changes in real estate, service lines, IT, and legal do not silently break program integrity.
Show Notes
- Exploring how 340B program performance is increasingly depending on claims data management and operational execution.
- Examining the challenges of reconciling fragmented systems across claims, EHRs, split billing, TPAs, wholesalers, and payer data.
- Highlighting the growing operational burden created by contract pharmacy expansion and manufacturer data-sharing requirements.
- Explaining why TPA configuration decisions are ultimately remaining the responsibility of the covered entity.
- Discussing why many health systems are operating multiple TPAs to accommodate varying retail pharmacy requirements.
- Distinguishing split billing and contract pharmacy as structurally different operational environments with separate oversight needs.
- Emphasizing the importance of accurate NPI, provider, and location data in maintaining program integrity.
- Describing the EHR as the practical source of truth driving downstream compliance and operational workflows.
- Identifying common causes of breakdowns, including connectivity failures, pharmacy switches, and internal change management gaps.
- Stressing the importance of monitoring anomalies and reconciliation failures before they are escalating into larger compliance risks.
- Exploring strategies for simplifying and scaling large 340B operations through stronger system integration.
- Arguing that dedicated 340B staffing and continuous oversight are becoming essential as operational complexity continues to grow.