When we consider 340B in relation to DSCSA compliance, two questions apply:
1) were you charged the appropriate price
2) did you charge the patient the appropriate price
In the DSCSA, a “shared responsibility” exists between the bill-to organization and the contract pharmacy. If your facility is a not-for-profit hospital that has a number of 340B contract pharmacies, from a DSCSA perspective, your hospital is required to be compliant. The data for each drug pedigree go to your hospital but accountability for the dose goes to each contract pharmacy.