Centralized Services Centers (CSC) provide a variety of services which could include filling patient-specific prescriptions and non-patient specific order fulfillment. Often CSCs provide service to both 340B covered entities and sites that are not qualified to purchase drugs at 340B prices.
When setting up a CSC, careful consideration should be paid to whether the CSC needs to be registered with Health Resources and Services Administration (HRSA) and the requirements that it must abide by to maintain compliance. For example, if the CSC is not owned by or part of a covered entity (CE) and is using its own National Provider Identifier (NPI) to fill prescriptions, it should consider registering as a contract pharmacy for each CE receiving service. If the CSC is using the dispensing pharmacy NPI, this is considered an in-house or CE dispensation which then would be subject to the GPO Prohibition for certain CE types. Furthermore, in this scenario the CSC must comply with the carve-in-/carve-out status of the CE, should be registered as a ship-to site, and non-eligible prescriptions must be filled using WAC.
When conducting order fulfillment for non-patient specific stock, best practice would be to add the address of the CSC as a ship-to address for each CE. If your CE has questions or concerns related to CSCs and compliance, feel free to email them to firstname.lastname@example.org.
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