Michael Glomb Advised Clinicians on 340B Audits

Michael Glomb, a Partner in the firm’s health care practice, spoke at a June 9 Clinical Network Retreat sponsored by the South Carolina Primary Health Care Association on Preparing for and Surviving a 340B Audit, a timely topic as audits of entities participating in the Federal 340B Drug Discount program are becoming increasingly frequent. Mr. Glomb described the differences between a manufacturer audit and a HRSA audit, and noted that both are designed to determine whether FQHCs have internal controls in place to assure that 340B drugs are not dispensed to individuals who are not their patients and that an FQHC does not cause a drug manufacturer to be subject to a so-called “duplicate discount.”  Mr. Glomb emphasized that developing clear policies and procedures and conducting periodic internal compliance reviews to assure that they are followed is critical to preparing for an external 340B audit.