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Grantee Combined Purchasing and Distribution Request for HRSA

Use this tool to submit a Combined Purchasing and Distribution Model (CPDM) request to the Health Resources and Services Administration (HRSA).

Each covered entity with a 340B ID is considered a separate entity for purposes of the 340B Program. HRSA assigns 340B IDs for stakeholders to confirm eligibility and appropriate shipment of 340B drugs. Because of the complex nature of grantees (other than health centers) and their organizational structures and relationships, the sharing of 340B inventory across 340B IDs is not allowed unless first approved by HRSA. There are multiple instances in which a grantee may wish to purchase a medication and distribute it to its sub-grantees. This is a common model with state health departments, which may purchase expensive medications at the state level and then distribute them to all their local health clinics and contracted providers who are also sub-grantees. Because these types of covered entities (CEs) do not have associated site or parent/child relationships in the 340B Office of Pharmacy Affairs Information System (340B OPAIS), they each have distinct 340B IDs and generally may not share inventory or purchase on a single account.

HRSA recognizes that there are unique situations in which this is necessary and has developed the opportunity for entities to submit proposals for approval of a combined purchasing account. This tool was designed to assist entities with that process.

The process of combining purchasing for multiple entities into one account may be used for different 340B IDs that all share the same 340B entity type and grant number. Organizations that have multiple 340B entity types (for example, a state health department with FP, STD, and TB grantees) or grant numbers of a single entity type (for example, sites that are all STD 340B types but with different grant numbers) may submit one proposal, but should clearly articulate separate purchasing accounts and inventory handling practices for each CE type/grant number. It is recommended that entities share only drugs purchased under one entity type/grant number with an entity of the same type/grant number with an approved model. Entities should clearly explain how all entities will ensure that the drugs will be dispensed to the appropriate patients.

Instructions:

Complete the form below to explain the combined purchasing ad distribution process.

  • Clearly and succinctly describe which 340B ID will be purchasing and which 340B ID(s) will be distributed to.
  • All combined purchasing and distribution models should be designed to comply with all 340B Program requirements, including prevention of duplicate discounts and diversion
  • Entities should ensure that they will maintain auditable records.
  • Include any pertinent details in addition to these items, as applicable.

Tips for request submission:

  • Ensure that the 340B OPAIS listing for each site is accurate prior to submission, including the authorizing official and primary contact, address, and grant number. Inaccurate information should be corrected using a change request through 340B OPAIS prior to proposal submission.
  • Use the CPDM Mapping Template to list all sites participating in the combined purchasing and distribution model. Each site and contract pharmacy listed should be active in 340B OPAIS (no future or terminated sites/pharmacies should be included in this submission).
  • Include a signed attestation from the authorizing official for each participating 340B ID to indicate agreement with this proposal.

After Submission:

  • A copy of the report will be emailed to the address provided.
  • HRSA may contact the submitter for additional information.