340B Compliance is a
Who is CiiTA?
We are a 340B consulting firm focused on helping pharmaceutical manufacturers understand their participation in the 340B Program. Our goal is to support manufacturers and covered entities working together to ensure that the 340B Program functions correctly. At CiiTA we understand that you work hard to provide the best possible care to your patients and that the 340B Program is a significant part of that care. CiiTA believes in the value of the Program and we are committed to supporting its sustainability.
CiiTA’s engagements are professional, transparent, and collaborative. We provide manufacturers with objective findings based on data analysis, and we communicate directly with you on behalf of manufacturers to review specific concerns. Further, CiiTA charges a flat fee to manufacturers for good faith inquiries, and never bills based on a percentage of recovery.
Why is CiiTA Contacting Us?
We all have to work together to promote 340B Program integrity. As participation in the Program continues to grow, sustainability relies on the careful management of issues such as duplicate discount and diversion.
Unfortunately, no participant in the 340B Program has sufficient visibility to prevent or identify issues on their own. Manufacturers have limited access to the data necessary to understand the Program. Because of this limited visibility, manufacturers need your help to resolve specific data concerns and to pinpoint the source of any issues.
What is a Good Faith Inquiry?
Based on HRSA guidance, a Good Faith Inquiry is a collaborative effort to resolve a manufacturer’s specific data concern related to a 340B purchase.
CiiTA’s Good Faith Inquiries are transparent and we share all findings with both the manufacturer and the participating covered entity. In some cases, concerns are resolved through simple dialogue; in other cases the parties agree to a limited data exchange. This helps bring all the puzzle pieces together for both groups.
What Will CiiTA Need From My Organization?
On behalf of a manufacturer, we may request a discussion of specific data concerns, a limited set of redacted data, or your participation in reviewing manufacturer data. We respect your time and strive to make the request as low-impact as possible.
At the end of the day, our goal is to create a 340B partnership between manufacturers and covered entities that will promote a successful and sustainable 340B Program and ultimately help you better serve your patients.
Develop Your 340B Strategy
CiiTA has, through extensive experience, developed a set of best practices to help guide you through the creation of your 340B strategy. Download our process document to facilitate the development of your strategy.