Executive summary. Preventing diversion takes defined eligibility rules, attributable records, exception review, and remediation, working ahead of the transaction rather than after it.
Definition
Diversion prevention controls are the policies, data checks, and review processes intended to prevent use of 340B drugs outside program requirements.
Build preventive and detective controls
Preventive controls require the necessary context before a program decision is recorded. Detective controls surface unusual locations, prescribers, quantities, or missing evidence for review.
A threshold alert is a prompt to investigate. Preserve the underlying facts and the reviewer’s conclusion alongside it.
Define the response path
Every exception needs an owner, investigation notes, a containment action, an outcome, and any repayment or corrective action the policy requires.
Track recurring root causes, such as interface timing or ambiguous location mapping, and change the process rather than closing the same exception again next month.
Frequently asked questions
Are all unusual transactions diversion?
No. An unusual pattern can be entirely legitimate. Review it against the applicable requirements and your documented policy.
Referenced standards and further reading
- HRSA: 340B program integrity ↗Health Resources and Services Administration
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