340B OPAIS Registration and Contract Pharmacy Reconciliation Log

This template is built to compare your 340B covered entity and contract pharmacy records against OPAIS. It focuses on active status, registered site address, site type, contract pharmacy listings, and effective or termination dates. It also gives you a place to document variances and assign corrective actions. It is not a general 340B policy manual; it is a working reconciliation log.

Most organizations use it on a monthly or quarterly cadence, and again whenever a site, contract pharmacy, or registration changes. A shorter review cycle is useful if you manage multiple pharmacies or have frequent contract updates. The right cadence is the one that lets you catch stale OPAIS data before claims, audits, or recertification reviews. If your change volume is high, monthly is usually easier to defend.

The log is usually completed by a 340B program manager, compliance analyst, pharmacy operations lead, or another designated reviewer who can access both OPAIS and internal contract records. A second-level management review is helpful for sign-off and escalation of discrepancies. The reviewer should be able to confirm what is active, what was terminated, and what supporting documentation exists. If the organization is decentralized, the reviewer should coordinate with site and pharmacy owners before finalizing the log.

Have the current OPAIS registration details, executed contract pharmacy agreements, internal site master records, and any termination or amendment notices ready. You should also have a list of active contract pharmacies and the dates each agreement became effective or ended. Without source records, the review becomes a guess instead of a reconciliation. This template includes a setup section to confirm the review period and source documents up front.

Common findings include a contract pharmacy still listed as active after termination, an address in OPAIS that no longer matches the internal site record, or a site type that does not match the covered entity designation. Reviewers also catch missing effective dates, outdated last-update information, and pharmacies left on the active list after an amendment. These are the kinds of discrepancies that create avoidable compliance exposure. The log is designed to surface them in one pass.

This template supports the recordkeeping and verification discipline expected in 340B program administration and audit readiness. It helps you maintain alignment between OPAIS, contract pharmacy agreements, and internal records, which is important for demonstrating controlled oversight. It does not replace legal review or HRSA guidance, but it gives you a repeatable control for day-to-day monitoring. Many covered entities use it as part of their broader compliance file.

Yes. You can add columns for site identifiers, parent organization, pharmacy chain, state, NPI, or internal contract owner if those fields help your workflow. Multi-site organizations often duplicate the reconciliation section by location or by contract pharmacy network. The key is to keep the comparison fields consistent so variances are easy to spot. Avoid adding so many custom fields that the active/inactive status becomes hard to read.

An ad hoc spreadsheet often captures only the current snapshot and leaves no clear trail for who reviewed what, when, and why a discrepancy was resolved. This template adds structure for scope, source records, variance tracking, and sign-off. That makes it easier to show a repeatable control during internal review or an external audit. It also reduces the chance that a terminated pharmacy stays on the active list by mistake.