Referral Capture & Compliance
Our team blends deep regulatory expertise with AI‑enabled technology, acting as your 340B analyst, 340B auditor, and strategic partner for 340B program management and 340B optimization.
340B Meaning—What the Program Intends to Do
At its core, 340B is designed to stretch scarce resources so safety‑net providers can do more for patients. In practice, that means using compliant 340B referral capture, robust governance, and disciplined operations to expand access, reduce total cost of care, and reinvest savings into community health.
An individual is not considered a patient of the Covered Entity if the only service received is the dispensing of drugs for self‑administration or administration in the home setting. Patients must receive bona fide health services from—or on behalf of—the CE; drug dispensing alone doesn't qualify.
The Cooper 340B A.C.E.™ Framework
(Assess • Capture • Execute)
We organize every engagement around our practical A.C.E.™ model—built to reflect what clients often search for as "340B ACE":
Differentiators That Move the Needle
Walgreens Referral Capture
Walgreens Referral Capture—Access That's Hard to Replicate
Cooper Strategy is one of only two sources CEs can use for reliable Walgreens referral capture assistance. Because Walgreens fills a significant share of U.S. prescriptions, ignoring these referrals can mean leaving substantial shared‑savings revenue on the table. Our direct access and data pipelines translate into:
AI‑Enabled + Human Expertise
Our platform ingests more provider‑patient data than typical referral solutions, then double‑scrutinizes every claim—first by AI, then by seasoned 340B experts—before capture, billing, or audit packaging. Benefits include:
AI + Human Expertise
Network Development
Pharmacy Network Development That Pays for Itself
We do the heavy lifting to stand up, expand, or rationalize your contract pharmacy network. Example: a CE we support wasn't contracted with nearby CVS pharmacies despite clear patient overlap. We coordinated with CVS/Wellpartner to register 18 sites with HRSA.
Patient Procurement—Compliant Growth With Telehealth
Cooper Strategy connects self‑insured employer populations with your Health Center or Hospital via telehealth, growing your unique patient panel and improving community access—without overwhelming staff.
Built‑in compliance via our partner, MakoRx:
Financial impact (typical models):
Why it matters:
This approach supports free or no‑copay medication programs, drives adherence, reduces ED utilization and hospital. This approach supports free or no‑copay medication programs, drives adherence, reduces ED utilization and hospitalizations, and strengthens equity—exactly what 340B was created to do.
How We Keep You Audit‑Ready
Our 340B audit services combine a mock‑audit package, HRSA/manufacturer/TPA audit support, and team training. With 50+ years of combined audit experience, we serve all six hospital‑based CE types and all health‑center entity types.
What sets our 340B program audits apart:
Mock Audit Package
Patient definition tests, referral chains, prescriber eligibility, location eligibility, compliance attestation, and variance root‑cause analysis.
HRSA Audit Support
On‑call response team; curated document rooms; pre‑brief/brief.
Training
Policy refreshers and practical "what auditors ask" sessions.
Technology
One‑click document bundles for auditors, CFOs, or Cooper teams.
Documentation: Getting Referral Capture Exactly Right
How we clearly record the referral in the patient's health record
We attach referral orders, encounter notes, and care‑coordination artifacts that link the referring provider, referred‑to provider, diagnosis, and therapy plan.
Our system stores patient care summaries and source documents, time‑stamped and permissioned at the CE's registered site.
Verifying provider encounters (referring & referred‑to)
Evidence shows the patient received health services from—or on behalf of—the CE, not just drug dispensing.
We maintain encounter provenance (who, when, where, why) and cross‑reference prescriber eligibility and location status.
How long after an encounter can a CE capture a referral?
HRSA does not prescribe a universal "X‑day" rule. What matters is a documented, clinically relevant provider‑patient relationship at the time of the 340B order. We help you adopt and enforce a defensible CE‑defined window (commonly aligned with your clinical follow‑up intervals) and ensure documentation supports medical necessity and continuity of care.
Obtaining specialist notes
We use traditional records exchange and add our proprietary patient care summaries to close gaps quickly.
Maintaining documentation at the CE site
All required artifacts are stored at the CE's registered site, reinforcing CE oversight.
Regular record audits
Scheduled and ad‑hoc reviews confirm that documentation remains complete, consistent, and compliant. Exceptions trigger root‑cause fixes, not just one‑off cleanups.
340B Program Management—From Policy to Performance
Why Cooper Strategy
Walgreens Referral Capture Access
One of only two sources available to CEs for reliable Walgreens referral capture assistance.
AI + Expert Review
Double-scrutinized claims with AI technology and seasoned 340B expert validation on every transaction.
Proven Audit Performance
100% success rate with "audit‑ready by design" documentation and comprehensive compliance support.
End-to-End 340B Consulting
Complete solution: analyst, auditor, and operator in one strategic partner for comprehensive program management.
What's Next
Request a 340B ACE Assessment
Identify gaps and quantify upside.
Schedule a Referral Capture Review
Walgreens‑originating referrals & network yield.
Book an Audit‑Readiness Check
Mock audit + remediation plan.