The Office of Pharmacy Affairs (OPA) has taken a critical look at the 340B database and has initiated several actions to increase its integrity. These actions, as explained below, have resulted in the deletion, consolidation, and termination of hundreds of database records. While these actions have reduced the overall number of entries in the database, the number of covered entities participating in the 340B program has continued to grow.

• 340B ID Number Changes: During the migration from the former OPA database to the current enhanced database, errors in naming convention for several 340B ID numbers were discovered. The enhanced database employs validation rules to standardize data entered into the system. While this will make the ID numbers for each entity type consistent, it will cause some changes to content. In the interest of completing the migration as quickly as possible, OPA staff changed the ID numbers to pass the required edits. Listed below are some of the types of errors that were discovered and what changes needed to be made.

  Ryan Whites that used to be designated as RW#, where # represented a number, will be changed to RWX, where X represents a Roman Numeral.

  Examples:
  RW1 are now RWI
  RW2 are now RWII
  RW2R are now RWIIR
  And so on…with one exception -- RW4 remains the same

  OPA has developed a crosswalk between old 340B ID numbers and any changes that might have been made to them. If the user accesses the old 340B ID record, there will be a link to the replacement ID. The following is an Excel spreadsheet that documents some of the changes that OPA was unable to reflect in the database – Converted ID Numbers

• Deleted Records Note: The original database was created in 1992 listing as many facilities as OPA could determine were potentially eligible to participate at that time, but in each case the Participating field was set to “No” until documentation registering that facility (the 340B Program Registration Form) was received. Many of those originally listed facilities never registered for the 340B Program, and therefore, have never participated in 340B. In addition, OPA did not systematically update information in those records.

  OPA has documented the 3,000+ "seeded" records identified above (i.e., records for those facilities that have never submitted a registration form) that have been deleted from the database. Deleted Records (Excel) is a spreadsheet listing the 340B ID#, Name of Entity, City, State, Date of Deletion, and Reason for Deletion.

• Consolidated Records Note: An additional effort has been made to consolidate records that OPA recognizes as duplicates. When the program began in 1992, there were separate funding streams, and therefore, separate entity identifiers for community health centers (CH), migrant health centers (MH), healthcare for the homeless programs (HO), school-based health centers (340S), and public housing primary care programs (PH). The Health Center Consolidation Act of 1996 brought all of those entities under Section 330 of the Public Health Service Act. Therefore, it is no longer necessary for OPA to identify them separately.

  As a result, all previously identified MH, HO, 340S, and PH covered entities have been terminated and assigned to a Consolidated Health Centers (CH) covered entity type. (CH formerly designated community health centers in the database.) For those affected records, the user will find a link to the record that replaces the old record. Because these are administrative corrections and NOT new covered entity registrations, the original add date for each has been retained and each remains a covered entity. These records are reflected with Termination Code = 10.

• Terminated Records Note: Users of the database may view and download records that have a Termination Date. Termination Dates, similar to Add Dates (which is the Effective Date for participation) occur on the first day of each calendar quarter. Many terminated records were a direct result of the consolidation of the CH records described above, while others are duplicate records for entities already participating. However, some of the terminations are due to the fact that a covered entity has lost its eligibility to participate in 340B. See the table at this link for a complete list of Termination Codes and Reasons used in the OPA database.

• Administrative Corrections
  Federally qualified health center look-alike (FQHCLA) covered entities are a special case. FQHCLA covered entities are designated as a "FQHCLA" entity type in the database. An FQHCLA, for all intents and purposes, has the same scope of health care services as a Consolidated Health Center. However, the FQHCLA does not receive Federal funding under Section 330. If an FQHCLA covered entity successfully competes for and receives Section 330 funding, OPA will make an Administrative Correction and terminate the FQHCLA covered entity as a "FQHCLA" entity type and simultaneously assign that organization a new 340B ID number as a "CH" entity type to accurately reflect its funding status. Because this is an administrative correction, the original Add Date (effective date) from the FQHCLA covered entity record will be used. There will be a link in the FQHCLA record to the new CH record. These records are reflected with Termination Code = 10.

Database Notes provide users of the 340B databases with topical information regarding changes made to the database to improve its integrity and utility. If you have any questions regarding the database or suggestions for further improvement, please send your questions and comments to opastaff@hrsa.gov.