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Reference answer · 340b-program · reviewed quarterly
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Q&A library · 340b-program

How is HRSA addressing duplicate discounts in Medicaid managed care 340B audits?

HRSA’s 2026 audits now focus on preventing duplicate discounts in Medicaid managed care claims, not just fee‑for‑service. Covered entities must prove claim‑level exclusion logic showing that managed care encounters using 340B drugs don’t also generate Medicaid rebates. Reliance on broad flags or verbal state guidance is no longer acceptable.

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