Program Integrity: FY14 Audit Results

Updated 2/20/19. The results chart includes audits where the findings have been finalized. Remaining audits are still under review. Information on Corrective Action Plans and Sanctions will be updated once approved by HRSA. HRSA recommends manufacturers do not contact audited entities regarding sanctions until a corrective action plan has been approved by HRSA and posted on this website.

Results Posted for 99 audits. 

Entity 340B ID State OPA Findings Sanction Corrective Action with Audit Closure Date
Albert Einstein Medical Center DSH390142 PA Diversion – 340B drug dispensed to an inpatient. Repayment to Manufacturers

Public letter to manufacturers (PDF – 30 KB)

Audit closure date: September 2, 2016

AltaMed CH093110 CA Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database. None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: May 15, 2015

Banner Desert Medical Center DSH030065 AZ

Diversion – 340B drugs dispensed at contract pharmacy for prescriptions written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 73 KB)

Audit closure date:  January 3, 2017.

Banner Estrella Medical Center DSH030115 AZ

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 75 KB)

Audit closure date:  January 10, 2017.

Banner Good Samaritan Medical Center DSH030002 AZ

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written by ineligible providers at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 28 KB)

Audit closure date:  January 5, 2017.

Banner Ironwood Medical Center DSH030130 AZ

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 116 KB)

Audit closure date:  January 3, 2017.

Banner Thunderbird Medical Center DSH030089 AZ

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 49 KB)

Audit closure date:  January 10, 2017.

Baptist Memorial Hospital – Tipton DSH440131 TN Incorrect 340B database record – incorrect entry for Primary Contact information. None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: June 25, 2015

Bellevue Hospital Center (NYCHHC) DSH330204 NY No adverse findings None

N/A

Audit closure date: November 12, 2015

Beth Israel Deaconess Medical Center DSH220086 MA

Diversion – 340B drugs dispensed to inpatients.

Duplicate discounts – Inaccurate information on Medicaid Exclusion File.

Repayment to manufacturers State Medicaid has since determined that duplicate discounts did not occur

Public letter to manufacturers (PDF – 12 KB)
Biggs Gridley Memorial Hospital CAH051311-00 CA

Incorrect 340B database record – Incorrect listing for entity’s name; orphan drug exclusion election was contrary to practice.

Entity did not provide contract pharmacy oversight.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Duplicate Discounts – Entity did not have controls in place to prevent duplicate discounts.

Repayment to manufacturers

Public letter to manufacturers (PDF – 14 KB)

Audit closure date: September 27, 2016

BMH, Inc. DBA Bingham Memorial Hospital CAH131325-00 ID

Incorrect 340B database record – registered contract pharmacy without a written contract in place.

Diversion – 340B drug dispensed at contract pharmacy, not supported by medical record.

Termination of contract pharmacy from 340B Program*

Repayment to manufacturers

Public letter to manufacturers (PDF – 42 KB)

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: January 28, 2016

Bon Secours Maryview Medical Center DSH490017 VA

Covered outpatient drugs obtained through a Group Purchasing Organization prior to March 12, 2015.

Incorrect 340B database record – pharmacies listed as contract pharmacies in error.

Diversion – 340B drugs dispensed for prescriptions written at ineligible sites and/or by ineligible providers.

Duplicate Discounts – Entity did not have controls in place to prevent duplicate discounts.

Repayment to manufacturers

Public letter to manufacturers (PDF – 86 KB)

Audit closure date: March 15, 2017

Cabell Huntington Hospital DSH510055 WV

Incorrect 340B database record – registered contract pharmacies without a written contract in place.

Diversion – 340B drugs dispensed to inpatients; 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites and/or by ineligible providers.

Termination of contract pharmacies from 340B Program*

Repayment to manufacturers

Public letter to manufacturers (PDF – 75 KB)

Audit closure date: May 24, 2016

CAMcare Health Corporation CH0211280 NJ

Incorrect 340B database record – registered contract pharmacy without a written contract in place.

Termination of contract pharmacy from 340B Program* Termination of contract pharmacy from 340B Program*

Audit closure date: July 2, 2015
Catholic Health Initiatives, Iowa, Corp. DSH160083 IA

Incorrect 340B database – Ineligible site registered on the 340B database.

Diversion – 340B drugs dispensed to inpatients.

Duplicate Discounts – Entity did not have controls in place to prevent duplicate discounts.

Termination of ineligible site from 340B Program*

Repayment to manufacturers

Public letter to manufacturers (PDF – 18 KB)

Audit closure date: March 29, 2016
Christus Spohn Hospital Kleberg DSH450163 TX

Diversion – 340B drug dispensed at contract pharmacy, not supported by medical record.

Repayment to manufacturers

Public letter to manufacturers (PDF – 78 KB)

Audit closure date:  January 17, 2017.

Columbus Community Hospital DSH450370 TX

Incorrect 340B database record – registered contract pharmacy without a written contract in place.

Diversion – 340B drug dispensed for prescriptions written by ineligible provider.

Repayment to manufacturers Public letter to manufacturers (PDF – 502 KB)

Audit closure date: September 22, 2015
Community Action Committee of Pike County CH052900 OH

Incorrect 340B database record – Entity was using contract pharmacies not listed on the 340B database.

Diversion – 340B drug dispensed at contract pharmacy for prescription written at ineligible site.

Duplicate Discounts – Entity was billing Medicaid contrary to information included in the Medicaid Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 117 KB)

Audit closure date: September 21, 2016

Coney Island Hospital (NYCHHC) DSH330196 NY

Covered outpatient drugs obtained through a Group Purchasing Organization prior to January 1, 2014.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written by ineligible providers at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 46 KB)

Audit closure date: February 17, 2016

County of Ventura CH098480 CA Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database; incorrectly listed names for registered sites. None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: August 21, 2015

Crozer Chester Medical Center DSH390180 PA

Incorrect 340B database – Contract pharmacy with written contract in place was not listed on the 340B database; offsite outpatient facilities were not listed on the 340B database; ineligible sites registered on 340B database.

Diversion – 340B drugs dispensed for prescriptions written at ineligible sites.

Duplicate Discounts – Entity did not have controls in place to prevent duplicate discounts.

Repayment to manufacturers

Public letter to manufacturers (PDF – 11 KB)

Audit closure date: March 7, 2018

DeKalb Medical Center, Inc. DSH110076 GA

Covered outpatient drugs were obtained through a Group Purchasing Organization.

Diversion – 340B drugs dispensed at contract pharmacy for prescription written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 198 KB)

Audit closure date: April 28, 2016

Dickinson College FP110081 PA Duplicate Discounts – Entity was billing Medicaid contrary to information included in the Medicaid Exclusion File. Medicaid number was incorrect on Medicaid Exclusion File. NPI number was not listed on Medicaid Exclusion File. Repayment to manufacturer

Public letter to manufacturers (PDF – 16 KB)

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: February 19, 2016

Florida Department of Health RWIID32304 FL No adverse findings None

N/A

Audit closure date: December 22, 2014

Frederick County Health Department RWI21702, TB21702 MD

For RWI21702, incorrect 340B database record – incorrect entry for Primary Contact.

None Covered entity self-terminated from 340B Program

Audit closure date: October 6, 2015
Goshen Medical Center, Inc. CH045800 NC

Incorrect 340B database record – registered contract pharmacy without a written contract in place. 

Entity did not provide contract pharmacy oversight.

None

Contract executed

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: November 10, 2015

Greenville Memorial Hospital DSH420078 SC

Incorrect 340B database record – Ineligible site registered on the 340B database.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written by ineligible providers at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 111 KB)

Audit closure date: July 18, 2018

Health Department of Northwest Michigan FP496591, FP497352, FP497206, FP49740 MI No adverse findings None

N/A

Audit closure date: December 11, 2014

Healthcare Connection, Inc., The CH059880 OH

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Registered contract pharmacies without written contract in place.

None

Database entry corrected

Contracts executed; 340B Program policies and procedures revised to address routine review of 340B Program database and contract pharmacy registration

Audit closure date: May 15, 2015

Heartland Regional Medical Center SCH260006 MO No adverse findings None

N/A

Audit closure date: January 28, 2015

Hermann Area Hospital District CAH261314-00 MO

Entity had inaccurate information in the 340B Medicaid Exclusion File. It was determined that duplicate discounts did not occur as a result of the finding.

None Public letter to manufacturers (PDF – 12.5 KB)

Audit closure date: October 13, 2015
Hilo Medical Center DSH120005 HI No adverse findings None

N/A

Audit closure date: September 19, 2014

Huron Regional Medical Center CAH431335-00 SD Diversion – 340B drug dispensed to inpatient. Repayment to manufacturers Public letter to manufacturers (PDF – 111 KB)

Audit closure date: October 13, 2015
Iberia Medical Center DSH190054 LA No adverse findings None

N/A

Audit closure date: March 9, 2015

ID Consultants and Infusion Care Specialists RWI28209 NC Diversion – 340B drugs dispensed at contract pharmacies to patients inconsistent with service for which grant funding had been provided. Repayment to manufacturers

Public letter to manufacturers (PDF – 41 KB)

Audit closure date: September 16, 2016

Jacobi Medical Center DSH330127 NY

Covered outpatient drugs obtained through a Group Purchasing Organization prior to September 2013.

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 45 KB)

Audit closure date: March 2, 2017

Jamaica Hospital Medical Center DSH330014 NY

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites; 340B drugs were not properly accumulated.

Repayment to manufacturers

Public letter to manufacturers (PDF – 57 KB)

Audit closure date:  March 8, 2017

Keck Hospital of USC DSH050696 CA

Incorrect 340B database record – duplicate registration for off-site outpatient facility; incorrect entries for Primary Contact, ship to addresses, and bill to addresses.

Diversion – Entity did not have adequate controls in place for proper accumulation and prevention of diversion; 340B drug dispensed at a contract pharmacy for a prescription written by an ineligible provider at an ineligible site.

Duplicate Discounts – inaccurate or incomplete information in Medicate Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 30 KB)

Audit closure date: September 15, 2016

Kossuth Regional Health Center CAH161353-00 IA

Diversion – 340B drugs were not properly accumulated; 340B drug dispensed at a contract pharmacy for a prescription written by an ineligible provider at an ineligible site.

Repayment to manufacturers

Public letter to manufacturers (PDF – 24 KB)

Audit closure date: September 15, 2016

Lakeland Regional Medical Center DSH100157 FL Incorrect 340B database record – Incorrect entries for Authorizing Official and Primary Contact information. None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: April 1, 2015

Lincoln Medical & Mental Health Center (NYCHHC) DSH330080 NY

Covered outpatient drugs obtained through a Group Purchasing Organization prior to February 3, 2014.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written by ineligible providers at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 45 KB)

Audit closure date: March 27, 2017

Logan Regional Medical Center DSH460015 UT

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers Public letter to manufacturers (PDF – 41 KB)

Audit closure date: September 22, 2015
Long Island Jewish Medical Center DSH330195 NY

Incorrect 340B database – Offsite outpatient facilities were not listed on the 340B database.

Diversion – 340B drug dispensed to an inpatient.

Duplicate Discounts – Inaccurate or incomplete information in the Medicaid Exclusion File.

Removal of contract pharmacy

Public letter to manufacturers (PDF – 134 KB)

Audit closure date: March 21, 2017

Madison County Community Health Center, Incorporated CH0516760 IN

Incorrect 340B database record – registered contract pharmacy without a written contract in place.

Entity did not provide contract pharmacy oversight.

Diversion – 340B drugs dispensed at contract pharmacy, not supported by a medical record; 340B drug dispensed at a contract pharmacy for a prescription written by an ineligible provider at an ineligible site.

Termination of contract pharmacies from 340B Program

Repayment to manufacturers

Public letter to manufacturers (PDF – 74 KB)

Audit closure date: October 23, 2017

Maine Medical Center DSH200009 ME Duplicate Discounts – Entity was billing Medicaid contrary to information in the Medicaid Exclusion File. None

State Medicaid has since determined that duplicate discounts did not occur

Public letter to manufacturers (PDF – 37 KB)

Audit closure date: November 13, 2015

McLeod Regional Medical Center DSH420051 SC

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database; closed offsite outpatient facility listed on database.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written by ineligible providers at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 77 KB)

Audit closure date: March 30, 2017

Medical University Hospital Authority DSH420004 SC

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Entity did not provide contract pharmacy oversight.

None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database and oversight of contract pharmacies

Audit closure date: September 1, 2015

Memorial Hermann Hospital System DSH450184 TX No adverse findings None

N/A

Audit closure date: December 16, 2014

Memorial Hospital Modesto DSH050557 CA

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database, incorrect entries for Authorizing Official, entity name and address information.

Diversion – 340B drugs were not properly accumulated; 340B drug dispensed to an inpatient.

Repayment to manufacturers

Public letter to manufacturers (PDF – 49 KB)

Audit closure date: September 13, 2016

Miami Children's Hospital PED103301-00 FL No adverse findings None

N/A

Audit closure date: December 11, 2014

Mount Sinai Hospital Medical Center DSH140018 IL

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites; 340B drugs were not properly accumulated.

Repayment to manufacturers

Public letter to manufacturers (PDF – 93 KB)

Audit closure date: March 15, 2017

Nathan Littauer Hospital DSH330276 NY

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Diversion – 340B drug dispensed to an inpatient; 340B drugs dispensed at contract pharmacies for prescriptions written by ineligible providers at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 201 KB)

Audit closure date: October 21, 2016

Neighborhood Improvement Project CH0438590 GA

Covered entity failed to maintain auditable medical records prior to May 2013 for one offsite outpatient facility and for one contract pharmacy.

Incorrect 340B database record – Offsite outpatient facility was not listed on the 340B database.

Entity did not provide contract pharmacy oversight.

Repayment to manufacturers

Public letter to manufacturers (PDF – 152 KB)

Audit closure date: October 21, 2016

New York Presbyterian Hospital DSH330101 NY No adverse findings None

N/A

Audit closure date: October 30, 2014

Newark Beth Israel Medical Center DSH310002 NJ

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written by ineligible providers at ineligible sites.

Repayment to manufacturer

Public letter to manufacturers (PDF – 40 KB)

Audit closure date: September 15, 2016

North Central Bronx Hospital Center (NYHCHHC) DSH330385 NY

Covered outpatient drugs obtained through a Group Purchasing Organization prior to December 2013.

Entity did not provide contract pharmacy oversight.

Incorrect 340B database record – ineligible site registered on the 340B database.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers

Contract pharmacy oversight demonstrated

Public letter to manufacturers (PDF – 43 KB)

Audit closure date: March 30, 2016

North Hudson Community Action Corporation CH024490 NJ

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database; entity failed to remove contract pharmacies from 340B database after contract was terminated; registered contract pharmacies without signed contracts in place.

Diversion – 340B drug dispensed at a contract pharmacy, not supported by a medical record; 340B drugs were not properly accumulated at contract pharmacy.

Duplicate Discounts – Inaccurate or incomplete information in the Medicaid Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 89.4 KB)

Audit closure date: March 30, 2016
Norton Hospital DSH180088 NY No adverse findings None

N/A

Audit closure date: March 30, 2015

Oklahoma State Department of Health FP74074 OK No adverse findings None

N/A

Audit closure date: November 6, 2014

Oklahoma State University Medical Center Trust DSH370078 OK No adverse findings None

N/A

Audit closure date: March 9, 2015

Olmsted Medical Center DSH240006 MN Incorrect 340B database record – registered contract pharmacy without a written contract in place; offsite outpatient facilities were not listed on the 340B database. Termination of contract pharmacy from 340B Program*

Database entry corrected

Termination of contract pharmacy from 340B Program*

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: August 31, 2015

Oswego Hospital SCH330218-00 NY Incorrect 340B database record – Registered outpatient facilities that were no longer part of entity. None Database entry corrected; 340B Program policies and procedures revised to address routine review of 340B Program database (Pending)

Audit closure date: October 13, 2015
Palmetto Health Baptist DSH420086 SC

Non-reimbursable facility incorrectly registered as child site.

Incorrect 340B database record – incorrect entries for physical addresses listed for entity and child sites,

Entity did not provide contract pharmacy oversight.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Termination of ineligible site from 340B Program*

Repayment to manufacturers

Public letter to manufacturers (PDF – 39 KB)

Audit closure date: August 12, 2016

Phelps County Regional Medical Center DSH260017 MO

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Duplicate Discounts – Inaccurate or incomplete information in Medicate Exclusion File.

None

State Medicaid has since determined that duplicate discounts did not occur

Public letter to manufacturers (PDF – 70 KB)

Audit closure date: March 18, 2016

Pioneers Memorial Hospital DSH050342 CA Incorrect 340B database record – Incorrect entries for billing and shipping addresses for offsite outpatient facilities. None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: March 31, 2015

Queens Hospital Center (NYCHHC) DSH330231 NY

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Covered outpatient drugs obtained through a Group Purchasing Organization prior to September 2013.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 46 KB)

Audit closure date: March 2, 2017

Regions Hospital DSH240106 MN

Incorrect 340B database record – duplicate registration for off-site outpatient facility.

Diversion – Entity did not have adequate controls in place for prevention of diversion.

Repayment to manufacturers

Public letter to manufacturers (PDF – 55 KB)

Audit closure date: August 12, 2016

Saint Agnes Medical Center DSH050093 NH Duplicate Discounts – Medicaid billing numbers were incorrect on the Medicaid Exclusion File. Repayment to manufacturers

Public letter to manufacturers (PDF – 27 KB)

Audit closure date: December 9, 2015

Saint Alphonsus Regional Medical Center DSH130007 ID

Covered outpatient drugs obtained through a Group Purchasing Organization prior to June 17, 2014.

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database; incorrect entries for addresses of off-site outpatient facilities; duplicate registration for off-site.

Diversion – 340B drugs dispensed to inpatients; 340B drug dispensed at contract pharmacy for a prescription written at an ineligible site.

Duplicate Discounts – Entity was billing Medicaid contrary to information included in the Medicaid Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 38 KB)

Audit closure date: July 15, 2016

Salem Hospital DSH380051 OR No adverse findings None

N/A

Audit closure date: November 20, 2014

Santa Clara Valley Medical Center DSH050038 CA

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Duplicate Discounts – Entity’s contract pharmacy was billing Medicaid without notification to HRSA.

None

State Medicaid has since determined that duplicate discounts did not occur. 

Public letter to manufacturers (PDF – 80 KB)

Audit closure date: January 3, 2017.

Seton Highland Lake CAH451365-00 TX No adverse findings None

N/A

Audit closure date: October 30, 2014

SF Community Clinic Consortium CH09107A CA

Incorrect 340B database record – incorrect entries for names for registered sites and registered an inactive site; registered contract pharmacies without written contract in place.

Duplicate Discounts – Entity was billing Medicaid contrary to information included in the Medicaid Exclusion File.

Termination of contract pharmacies from 340B Program*

Repayment to manufacturers

Public letter to manufacturers (PDF – 82 KB)

Audit closure date: March 8, 2017

Slidell Memorial Hospital DSH190040 LA

Incorrect 340B database record – incorrect entries for Authorizing Official and Primary Contact information.

Entity did not provide contract pharmacy oversight.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers Public letter to manufacturers (PDF – 199 KB)

Audit closure date: June 8, 2015
Sonoma County Indian Health Project, Inc. FQHC638018 CA No adverse findings None

N/A

Audit closure date: December 22, 2014

Southern Illinois Healthcare Foundation CH053320 IL No adverse findings None

N/A

Audit closure date: September 25, 2014

Spectrum Health Reed City Hospital CAH231323-00 TX No adverse findings None

N/A

Audit closure date: November 13, 2014

St. John Hospital & Medical Center DSH230165 MI

Incorrect 340B database record – Registered contract pharmacies without written contract in place.

Duplicate Discounts – Incomplete information in the Medicaid Exclusion file.

Repayment to manufacturers

Public letter to manufacturers (PDF – 27 KB)

Audit closure date: March 15, 2016

St. Joseph Hospital of Orange DSH050069 CA Incorrect 340B database record – incorrect entries for billing and shipping addresses for outpatient facilities. None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database (Pending)

Audit closure date: October 13, 2015

St. Vincent Health Center DSH390009 PA

Diversion – 340B drugs dispensed for prescriptions written by ineligible providers at ineligible sites.

Duplicate Discounts – Entity was billing Medicaid contrary to information in the Medicaid Exclusion File.

Repayment to manufacturers

State Medicaid has since determined that duplicate discounts did not occur.

Public letter to manufacturers (PDF – 76 KB)

Audit closure date: March 27, 2017

St. Vincent Hospital and Health Care Center DSH150084 IN

Incorrect 340B database record – registered contract pharmacies without a written contract in place.

Duplicate Discounts – entity was billing Medicaid contrary to information in the Medicaid Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 11 KB)

Audit closure date: September 27, 2016

Sunset Park Health Council, Inc. CH0218870 NY

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database; registered contract pharmacies without written contract in place.

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Duplicate Discounts – Entity was billing Medicaid contrary to information included in the Medicaid Exclusion File.; inaccurate or incomplete information in Medicaid Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 82 KB)

Audit closure date: September 15, 2016

The New London Hospital Association, Inc. CAH301304 -00 NH No adverse findings None

N/A

Audit closure date: May 5, 2015

Transylvania Community Hospital dba Transylvania Regional Hospital CAH341319-00 NC

Covered entity was purchasing orphan drugs through the 340B Drug Pricing Program contrary to its listings on the 340B database.

Diversion – 340B drugs dispensed to inpatient.

Repayment to manufacturers Public letter to manufacturers (PDF – 40 KB)

Audit closure date: April 20, 2016
Tucson Medical Center DSH030006 AZ

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database.

Diversion – 340B drugs dispensed at the entity and contract pharmacies for prescriptions written at ineligible sites, not supported by a medical record.

Repayment to manufacturers

Public letter to manufacturers (PDF – 15 KB)

Audit closure date: August 12, 2016

UCI Medical Center DSH050348 CA Incorrect 340B database record – Incorrect entries for DSH percentage and shipping address. None

Database entry corrected

340B Program policies and procedures revised to address routine review of 340B Program database

Audit closure date: May 15, 2015

UCSD Medical Center DSH050025 CA Duplicate Discounts – Incomplete information on the Medicaid Exclusion File. Repayment to manufacturers

Public letter to manufacturers (PDF 101 KB)

Audit closure date: August 12, 2016

UCSF Medical Center DSH50454 CA

Diversion – 340B drugs dispensed at contract pharmacies for prescriptions written at ineligible sites.

Duplicate Discounts – Inaccurate or incomplete information in Medicaid Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 19.9 KB)

Audit closure date: September 15, 2016

United Community Health Center – Maria Auxiliadora, Inc. CH093590 AZ

Incorrect 340B database record – offsite outpatient facilities were not listed on the 340B database; entity failed to remove contract pharmacies from 340B database after contract was terminated.

Entity did not provide contract pharmacy oversight.

Diversion – 340B drugs dispensed at contract pharmacy for prescriptions written at ineligible sites.

Repayment to manufacturers

340B Program policies and procedures revised to address oversight of contract pharmacies

Public letter to manufacturers (PDF – 11.4 KB)

Audit closure date: May 24, 2016

University Health System DSH450213 TX

Incorrect 340B database record – registered contract pharmacy without a written contract in place.

Diversion – 340B drugs dispensed to inpatients; 340B drugs dispensed at entity and contract pharmacies for prescriptions written at ineligible sites.

Repayment to manufacturers

Contract executed

Public letter to manufacturers (PDF – 138 KB)

Audit closure date: January 10, 2017.

University of California Davis Medical Center DSH050599 CA

Incorrect 340B database record – Ineligible sites registered on the 340B database; offsite outpatient facility was not listed on the 340B database.

None

Public letter to manufacturers (PDF – 97 KB)

Audit closure date: September 15, 2016

University of Chicago Medical Center DSH140088 IL Diversion – 340B drugs dispensed for prescriptions written at ineligible sites. Repayment to manufacturers

Public letter to manufacturers (PDF – 11 KB)

Audit closure date: August 12, 2016

University of Kentucky DSH180067 KY

Diversion – 340B drug dispensed at contract pharmacy, not supported by medical record; 340B drugs dispensed at contract pharmacy for prescription written at ineligible site.

Repayment to manufacturers Public letter to manufacturers (PDF – 31 KB)

Audit closure date: October 15, 2015
University of Missouri Health Care DSH260141 MO

Incorrect 340B database record – Offsite outpatient facilities were not listed on the 340B database; ineligible site registered on the 340B database.

Diversion – 340B drugs were not properly accumulated.

Termination of ineligible sites from 340B Program*

Repayment to manufacturers

Public letter to manufacturers (PDF – 158 KB)

Audit closure date: February 14, 2018

University of Texas Medical Branch DSH450018 TX

Covered outpatient drugs obtained through a Group Purchasing Organization prior to August 9, 2013.

Diversion – 340B drugs dispensed for prescriptions written at ineligible sites.

Repayment to manufacturers

Public letter to manufacturers (PDF – 89 KB)

Audit closure date: January 17, 2017.

UPMC Mercy DSH390028 PA

Incorrect 340B database record – Incorrect entries for offsite outpatient facilities addresses.

Diversion – 340B drugs were not properly accumulated.

Repayment to manufacturers Public letter to manufacturers (PDF – 24 KB)

Audit closure date: April 14, 2016
Vanderbilt University Hospital and Clinic DSH440039 TN

Duplicate Discounts – Inaccurate or incomplete information in Medicaid Exclusion File.

Repayment to manufacturers

Public letter to manufacturers (PDF – 39.2 KB)

Audit closure date: October 21, 2016

West Jefferson Medical Center DSH190039 LA No adverse findings None

N/A

Audit closure date: July 1, 2014

*Note: Covered entity self-terminated cited facilities prior to termination of facilities by OPA.

Date Last Reviewed:  February 2019