Virtue 340B
Stewarding 340B for Sustainable Patient Impact

Turning 340B rules into meaningful impact is rarely a straightforward process. Many organizations recognize the value of the federal 340B Drug Pricing Program but struggle to govern it effectively. Oversight often sits with external vendors who operate the software, apply the rules and generate reports, leaving internal teams with limited visibility or control.

Virtue 340B helps healthcare organizations mature from vendor-dependent, reactive compliance models to a disciplined and transparent stewardship of the federal 340B Drug Pricing Program.

The need for that shift becomes clearer over time. While savings may be reported, risk can quietly build beneath the surface. Hospital leaders assume the program is being managed correctly and step in only when audits or manufacturer restrictions force action. When rules shift, responses are often corrective rather than deliberate and strategic, leaving programs and patients vulnerable.

As an independent compliance and governance advisory firm dedicated to the 340B program, Virtue 340B helps healthcare organizations enhance the maturity of their internal governance at an organization-wide level. The result is a program that is not just compliant but strategically managed to deliver lasting value.

“Strong 340B programs are not built on maximizing margin,” says Edward Vargas, CEO. “They are built on trust, documentation and accountability.”

This principle underpins every engagement. Virtue assesses program integrity, identifies hidden compliance exposure and clarifies where reported savings are truly defensible. Targeted audits and ongoing compliance reviews bring structure and accountability to programs. Quarterly audits are risk-targeted, focusing on high-volume sites, contract pharmacies and workflows with the most potential compliance or financial impact. The outcome is clearer decision-making and a compliance model that leadership can support with confidence.

Maximizing Savings Across Multi-Site Operations

Virtue 340B never relies on a one-size-fits-all approach to client engagement. The team begins by understanding each client’s operational reality, not just the theoretical rules or assumed 340B elements on paper.

For organizations with multiple sites, Virtue examines workflows at each location individually, verifying provider and patient eligibility and assessing consistency in purchasing, documentation and oversight across all facilities. Once opportunities for standardization of processes are identified, best practices that work across the organization are implemented.

The same careful lens applies to contract pharmacies. Each relationship is reviewed independently, including accumulator logic and platform configurations, to ensure alignment across covered entities, third-party administrators and all participating sites.

During one engagement, Virtue identified inconsistent eligibility configurations across a client’s contract pharmacies, all of which were operating under the same administrator. Some pharmacies applied overly strict rules, leaving legitimate savings unclaimed. Others applied looser controls, exposing the organization to compliance risk. Auditing each pharmacy independently and analyzing captured and non-captured claims, Virtue helped establish a single standardized configuration aligned with the client’s compliance plan.

The result was higher legitimate savings, reduced diversion risk, stronger audit readiness and renewed confidence at the leadership level.

An Objective Lens on Risk and Savings

Vendor-agnostic independence is key to achieving meaningful results. Virtue does not sell technology, manage claims or operate pharmacies. That separation allows the firm to serve as an unbiased compliance voice, evaluating systems and decisions. Clients gain a fair view of where savings are real, where risk may be hidden and how decisions align with long-term program integrity.

The same clarity guides Virtue’s work around the shifting compliance policies. Virtue 340B stays ahead by monitoring updates in real time. The team evaluates how new restrictions affect contract pharmacies, third-party administrators, and multi-site operations, assessing both immediate and downstream impacts. Internal auditing processes are then adjusted to address emerging needs, ensuring clients remain compliant while minimizing risk.

Communication is equally important. Virtue presents guidance in clear, everyday language, avoiding legal jargon and allowing internal teams to fully digest and act on the information. Clients value this proactive approach because it prevents reactive fixes after issues arise. When necessary, Virtue also helps draft and establish documentation that can be confidently defended during HRSA audits or other external reviews.

Education completes the model. Virtue does not aim to manage programs on behalf of clients. The goal is to equip internal teams to administer them with confidence. Training is tailored by role, grounded in real workflows and often built around the client’s own data. Generic webinars give way to practical understanding. Teams leave informed rather than overwhelmed, with stronger internal conversations on program operations and reduced dependence on external vendors for daily interpretation.

The future of the 340B program will favor organizations that operate transparently and maintain governance structures that can withstand scrutiny over time. Virtue 340B leads the way.