Transition checklist
How do you switch 340B TPAs?
A four-phase plan for changing your 340B third-party administrator without losing claims, data or compliance coverage.
Phased timeline
Four phases of a 340B TPA switch
- 1Phase 1
Before notice
- 2Phase 2
Data handoff
- Request claim-level history, accumulators/virtual inventory positions, eligibility rules and filters (prescriber lists, locations, encounter lookbacks), NDC mappings, open replenishment orders and reports.[3][4]
- Decide whether inventory and accumulations transition to the new TPA, or the covered entity reconciles old inventory and starts fresh.[3]
- 3Phase 3
Cutover
- Set a hard cutover date; the new TPA qualifies claims from that date.
- Confirm Medicaid carve-out / duplicate-discount controls continue at each contract pharmacy.[1]
- Confirm OPAIS records, names and addresses match the written pharmacy contracts.[1][2]
Note: New contract pharmacies can only be registered in OPAIS during Oct 1–15, Jan 1–15, Apr 1–15 and Jul 1–15, and start the next quarter; the Authorizing Official must attest within 15 calendar days. If a switch also adds pharmacies, plan around those windows.[1]
- 4Phase 4
Run-out and oversight
- Verify the old TPA stopped qualifying claims after its end date — a real case found a prior TPA kept qualifying claims after its contract ended.[5]
- Reconcile reversals, returns and replenishment, and keep auditable records.[1]
- If diversion or duplicate discounts are found, self-disclose to HRSA at 340bselfdisclosure@hrsa.gov.[1][6]
Data handoff
What to get from your outgoing TPA
Request these before notice takes effect.[3][4]
| Data item | Why it matters |
|---|---|
| Claim-level history with qualification reason | Shows why each claim was treated as 340B, so past decisions stay auditable after the switch. |
| Accumulators / virtual inventory by NDC and pharmacy | Determines whether positions carry over to the new TPA or are reconciled and reset. |
| Eligibility rules and filters | Prescriber lists, locations and encounter lookbacks must be rebuilt consistently in the new system. |
| Pharmacy and location list | Every contract pharmacy needs to stay active and match its OPAIS record. |
| Open orders and true-up balances | Pending replenishment and balances need a clear owner at cutover. |
| Reports and audit trail | Supports auditable records and future audits after access to the old system ends. |
| Any known compliance exceptions | Open issues travel with the covered entity, not the vendor. |
Common pitfalls
- Overlapping qualification by both vendors
- Accumulators lost at cutover
- Pharmacy name/address mismatches with OPAIS
- Medicaid carve-out gaps
- Losing data access after termination
Who is accountable during a switch?
Per HRSA, the covered entity remains responsible for its contract pharmacy arrangements and must maintain auditable records. HRSA recommends quarterly internal audits and annual independent audits.[6] A TPA change does not move that responsibility.
How Aventi helps
A transition planned with your team
Aventi is an independent 340B TPA for contract pharmacy and split billing, trusted by 300 covered entities, 24 of them hospitals. We plan the transition with your team and your outgoing vendor's data, and the rebate module is Included for Aventi TPA clients. See how TPAs compare in our 340B TPA comparison.[7]
FAQ
Switching 340B TPAs: common questions
It depends on your current contract's notice period, the number of contract pharmacies and the quality of the data you get from the outgoing TPA. If the switch also adds new contract pharmacies, timing is tied to HRSA's quarterly OPAIS registration windows (Oct 1–15, Jan 1–15, Apr 1–15, Jul 1–15), with new pharmacies starting the following quarter.[1]
Registration is tied to the covered entity's written contract with each pharmacy, not to the TPA, so changing the TPA alone doesn't create a new registration. Any new pharmacy or changed pharmacy contract must match OPAIS exactly and be registered in an open window. We recommend confirming your records with HRSA/OPAIS.[1][2]
Your contracts should state whether inventory and accumulations transition to the new TPA or whether the covered entity reconciles old inventory and resets.[3]
The run-out terms in the outgoing TPA agreement govern those claims. Define them before you give notice.[3]
Avoid it. Set one cutover date and verify that the outgoing TPA stops qualifying claims after its end date.[5]
Yes. The covered entity remains responsible for its contract pharmacy arrangements and must maintain auditable records throughout the switch.[6]
Rebate claim submission for the 2027 340B rebate model should be planned with your new TPA as part of the transition. Aventi's rebate module is Included for Aventi TPA clients. See the 340B rebate model and managing 340B rebates across multiple TPAs pages for more.340B rebate model · Managing 340B rebates across multiple TPAs
Sources
- HRSA, Contract Pharmacy Services — https://www.hrsa.gov/opa/implementation-contract
- HRSA, Registration — https://www.hrsa.gov/opa/registration
- Ogunsusi, "Pharmacy, TPA and PBM Contracting," 340B Grantees Conference (Oct 2022) — https://rwc340b.org/wp-content/uploads/2022/10/Ogunsusi-Pharmacy-TPA-PBM-Contracting-October-2022-340B-Grantees-Conference-D1025629-2.pdf
- NCSD, 340B Contract Pharmacy Guide (2021) — https://ncsddc.org/wp-content/uploads/2021/10/NCSD-340B-Contract-Pharmacy-Guide-10.12.21.pdf
- Visante, Strategic Collaboration for Sustained 340B Success (Benefis Health System case study) — https://www.visante.com/insights/case-studies/a-strategic-collaboration-for-sustained-340b-success-at-benefis-health-system/
- HRSA FAQ, What are the audit and compliance parameters under the contract pharmacy guidelines? — https://www.hrsa.gov/about/faqs/what-are-audit-compliance-parameters-under-contract-pharmacy-guidelines
- Aventi Health, 340B TPA comparison — https://aventihealth.com/340b-tpa-comparison
Last updated November 9, 2026.