Manufacturers + payers + state Medicaid + HRSA

Pharmacy and 340B Diversion

Manufacturer-payer-covered-entity neutral attestation on 340B duplicate discounts, contract pharmacy chain depth, and off-label dispensation. CREB packets usable by either side in litigation.

The 340B dispute landscape

Understanding the Complexities of 340B Disputes

The 340B Drug Pricing Program, established to stretch scarce federal resources, has become a focal point for disputes between manufacturers, payers, and covered entities. These disputes often center around duplicate discounts, contract pharmacy chain depth, and off-label dispensation. JIL Sovereign provides a neutral ground for attestation, ensuring that all parties have access to credible, court-ready evidence bundles.

The total addressable market (TAM) for resolving 340B disputes ranges from $200M to $500M, highlighting the significant financial exposure at stake in these manufacturer-payer-covered-entity disputes.

How JIL attests

JIL's 18-Check Attestation Process

JIL Sovereign employs a rigorous 18-check attestation process to verify the integrity of 340B transactions. This process ensures that all aspects of the dispute--from duplicate discounts to contract pharmacy chain depth and off-label dispensation--are thoroughly examined and documented.

Each check is a declarative rule registered in the existing check catalog, referencing dimensions on the AVA hypercube and producing signed integrity findings.

Duplicate discount detection

Precise Detection of Duplicate Discounts

One of the core functionalities of JIL Sovereign is the precise detection of duplicate discounts in 340B transactions. By cross-referencing authoritative datasets, JIL identifies instances where discounts have been improperly applied more than once, providing clear evidence for litigation.

This detection capability is crucial for maintaining the integrity of the 340B program and ensuring that all parties adhere to the established guidelines.

Contract pharmacy chain validation

Validating Contract Pharmacy Chains

JIL Sovereign validates the depth and legitimacy of contract pharmacy chains involved in 340B transactions. This validation process ensures that pharmacies are properly authorized and that the chain of custody for medications is intact, preventing fraudulent activities.

By providing detailed evidence bundles, JIL enables all parties to confidently address any discrepancies in contract pharmacy chains.

Pricing

Transparent and Fair Pricing

JIL Sovereign offers transparent and fair pricing for its attestation services, ensuring that all parties have access to the evidence they need without undue financial burden.

Pricing -- Fraud Pillar Standard

One model. Bottom-line aligned.

Retroactive scan
one-time, scoped to volume
4-year minimum lookback. Builds the base dataset. Proves the closed-loop economics before the flat-fee leg starts.
Flat fee
12.5% of disclosed PI spend
Annual, capped. Covers nightly T1 + AVA + T2 + CREB(TM) generation. Below the industry-standard 15 to 25% SIU contingency.
Contingency
10% of net cash recovered
Performance-aligned. Fires only on actual recovered cash, net of MAC appeal, settlement, and pursuit. Outside counsel runs 33%.
90-day pilot
$1M all-in, asymmetric downside
If Day 90 deliverables miss, the $1M converts to a 6-month platform credit and contingency drops from 10% to 7.5%. No other vendor in PI takes pure downside on the math.

Pricing anchored to public 10-K Schedule H disclosures + CMS PERM 2024. UHG-scale case study available at /products/mco-flat-fee.

90-day pilot

Experience JIL Sovereign with a 90-Day Pilot

To demonstrate the value of our attestation services, JIL Sovereign offers a 90-day pilot program. This pilot allows organizations to experience the benefits of our platform firsthand, with no long-term commitment required.

During the pilot, organizations can access up to 18 checks, validate contract pharmacy chains, and receive court-ready evidence bundles, all within a risk-free environment.