The Importance of 340B Medicaid Billing Audits

How often do you review your Medicaid billing rules for 340B?
In my experience as an auditor of 340B entities for 13+ years, covered entities are quite invested in preventing duplicate discounts with Medicaid through routine payer code review, ensuring an accurate listing on the Medicaid Exclusion File, and claims review.  At the same time, a comprehensive review of rev codes, status indicators, NDC placement and accuracy of actual acquisition cost (AAC) or modifiers isn’t always part of the regular audit cycle. 

At Rx|X, we’re excited to introduce our Medicaid Billing Compliance Audit, a focused review designed to give covered entities confidence in their 340B Medicaid claims.

Our audit evaluates:
🔹 AAC billing accuracy where applicable
🔹 Modifier and submission code consistency
🔹 Alignment with HRSA and state-specific Medicaid rules
🔹 Medicaid Exclusion File and NPI configuration integrity

This review mirrors HRSA’s audit expectations but goes a step further to helps entities identify billing vulnerabilities before they become findings. Because compliance confidence starts with clean, defensible claims.

Case Study: in 2024, Rx|X worked with a hospital system to update Medicaid billing rules in Epic following a change in State policy. This involved an analysis of current versus future state of modifiers across several status indicators for fee-for-service and managed care plans. It also reviewed the process for updating actual acquisition cost data to ensure the 340B price is accurately communicated to the State. 

If you are interested in learning more about how Rx|X can help you with your Medicaid billing integrity, email us at info@rxxconsulting.com!