When implemented strategically, referral capture can generate meaningful savings for 340B covered entities—savings that translate into expanded access to care and strengthened program sustainability. Still, despite its potential, referral capture is often sidelined due to its perceived complexity.
This white paper outlines key considerations for building a compliant, high-performing referral capture program—from stakeholder alignment to documentation best practices—helping 340B entities reclaim value and reinforce program integrity.
Why Referral Capture Remains Underutilized
Across health systems, referral capture programs have the potential to unlock significant 340B savings annually. In some cases, the recovered funds can support new provider positions, fund specialty services, or underwrite infrastructure investments.
So why do so many covered entities underinvest in referral capture? The answer is straightforward: it’s complicated.
Referral capture requires close coordination between departments, clear documentation protocols, and reliable access to encounter and referral data. Without a deliberate strategy, many covered entities find themselves navigating compliance risk or operational bottlenecks.
Common Challenges in Referral Capture
Developing a sustainable and compliant referral capture program involves overcoming a few familiar barriers:
- Cross-functional alignment Successful referral capture requires buy-in from pharmacy, compliance, finance, IT, and clinical leadership. Without shared understanding and coordinated roles, efforts can stall or become siloed.
- Disparate data sources Referral documentation and patient encounters often span multiple EHRs and provider systems. Gaining timely, accurate access to these data sources is critical—and frequently challenging.
- Program upkeep Referral capture programs are not set-it-and-forget-it. Without ongoing audits, stakeholder engagement, and data-driven performance tracking, even strong programs can lose traction over time.
Despite these hurdles, organizations that commit to strategic referral capture often see a significant return on investment—in both savings and patient impact.
Five Foundations of a High-Impact Referral Capture Program
To build or revitalize your referral capture strategy, consider the following best practices:
Align Internal Stakeholders Early
Start by ensuring all key departments understand the why behind referral capture. Pharmacy leads should be involved in claims capture, IT teams must support data access, and compliance leaders ensure the program aligns with 340B requirements.
Define roles and responsibilities clearly. Foster a shared mission-driven narrative: referral capture isn’t just about compliance—it’s about expanding care for the communities you serve.
Document a Program Policy
A written policy is essential for ensuring consistent execution and audit readiness. It should include:
- Eligibility criteria
- Documentation and workflow standards
- Stakeholder responsibilities
- Alignment with your organization’s care delivery model and EHR systems
Tailoring the policy to your organization’s specific infrastructure helps operationalize compliance and builds trust across departments.
Integrate with IT and Data Teams
Referral capture hinges on data access and validation. Collaborate with IT and EHR analysts to:
- Identify where referral orders and encounter notes are housed
- Automate data pulls where possible
- Create storage and audit trails for documentation
Customization of reports or EHR workflows may be necessary to streamline data visibility and reduce manual work.
Audit and Evaluate Regularly
Ongoing audits help maintain compliance and performance. Regularly review a sample of referral claims to validate that:
- Documentation is complete
- Encounter timelines are met
- Eligibility criteria are satisfied
Use dashboards or KPIs to track capture rates, missed opportunities, and denial reasons. Share insights across teams to reinforce program value and make improvements.
Adapt to Change
Referral capture must evolve alongside your organization. Whether it’s EHR upgrades, care delivery shifts, or regulatory updates, your program should remain nimble.
Build time into your roadmap for reassessing workflows, updating policies, and re-educating staff. Foster a culture where teams are empowered to suggest improvements and report issues early.
Conclusion: A Strategic Imperative
In a landscape of industry unknowns, 340B referral capture is no longer a “nice to have”—it’s a strategic imperative. By aligning teams, codifying processes, and monitoring results, covered entities can unlock a steady stream of 340B savings while reinforcing compliance and advancing their mission.
About the Author:
Kristin Fox-Smith (MPA) brings more than 20 years’ experience to Visante clients as Managing Director. Specializing in specialty pharmacy assessments and implementations, Kristin also has expertise in coding and billing issues for oncology, solid organ transplant and bone marrow services, inpatient and outpatient mental health, and long-term care and HIV/AIDS.
