Common Errors in ESP Data Submissions & How to Fix Them

ESP has become an essential compliance tool for covered entities participating in the 340B Drug Pricing Program. While ESP helps prevent duplicate discounts and ensures manufacturer compliance, many covered entities struggle with common data submission errors that can lead to pricing delays, compliance risks, and even loss of 340B eligibility at contract pharmacies.

1. Missing or Incomplete Data Fields

The Problem:

ESP requires precise data for every submission, including NDC codes, unique NPI numbers, prescription numbers, dispense dates, and contract pharmacy identifiers. Missing or incomplete fields can lead to failed submissions or delayed 340B pricing reinstatement.

How to Fix It:

• Automate data extraction: Use TPAs to ensure all required fields are included in ESP submissions.
• Implement data validation tools: Run a pre-submission check to flag missing or incomplete entries before uploading.
• Standardize internal data collection: Train pharmacy staff and IT teams to ensure all data is consistently recorded.

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How to Fix It:

• Maintain an up-to-date contract pharmacy directory: Regularly verify HINs and NPIs in your ESP account.
• Cross-check pharmacy IDs before submission: Ensure that identifiers match manufacturer-approved records.
• Use reporting tools from TPAs to validate contract pharmacy information before submitting claims.

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2. Late or Missed Submissions

The Problem:

Most manufacturers require ESP data uploads twice per month (typically on the 1st and 15th). Late submissions can result in lost pricing for the period, forcing covered entities to pay full price for medications.

How to Fix It:

• Set automated reminders and schedules: Implement calendar alerts for submission deadlines.
• Establish internal workflows: Assign responsibility to a dedicated compliance team member.
• Monitor manufacturer submission windows: Some manufacturers have shorter lookback periods—ensure claims are submitted within the allowed timeframe.

3. Submitting Claims Outside the Manufacturer’s Lookback Period

The Problem:

Each manufacturer enforces a lookback period (e.g., 45 days from the dispense date) for claim submissions. Submitting claims beyond this period can lead to rejection of 340B pricing.

How to Fix It:

• Regularly check manufacturer policies: Ensure claims are submitted within each manufacturer’s allowed timeframe.
• Automate reporting schedules: Extract and submit eligible claims as soon as they are recorded.
• Implement real-time monitoring: Identify claims approaching the lookback period and flag them for immediate processing.

4. Duplicate or Overlapping Submissions

The Problem:

Submitting the same claims multiple times or overlapping datasets can trigger ESP system errors or manufacturer disputes.

How to Fix It:

• Maintain a centralized tracking system: Keep a record of all submissions, ensuring no duplicates are sent.
• Use batch processing tools: Some TPAs offer deduplication features that prevent duplicate uploads.
• Verify submission history in ESP: Cross-check previous uploads before submitting new claims.

5. Incorrect NDC or Drug Data

The Problem:

ESP submissions must match the exact NDC (National Drug Code) and drug information as recognized by the manufacturer. Any discrepancies can lead to pricing denials or compliance flags.

How to Fix It:

• Use manufacturer-approved NDC lists: Ensure all drugs submitted are eligible for 340B pricing under contract pharmacy agreements.
• Validate NDC entries: Use systemized data entry to prevent manual errors.
• Regularly update formularies: Work with TPAs and wholesalers to maintain accurate, current NDC lists.

6. Failure to Address ESP Feedback & Error Notifications

The Problem:

ESP provides real-time feedback on data submissions. Ignoring system alerts or failing to correct errors can delay pricing reinstatement and compliance approval.

How to Fix It:

• Regularly check ESP dashboards: Designate a team member to monitor submission statuses and flag errors for correction.
• Respond promptly to error messages: Investigate flagged issues and resubmit corrected data as soon as possible.
• Keep communication open with manufacturers: If unclear about an error, engage with ESP or the manufacturer for clarification.

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7. Inconsistent Submission Formats

The Problem:

ESP enforces strict file formatting rules. Any inconsistencies in file structure, column names, or data formatting can cause submission failures.

How to Fix It:

• Follow ESP submission templates: Ensure all uploads match ESP’s required formats.
• Use automated report generation tools: Leverage software solutions that export data in ESP-compatible formats.
• Test uploads before final submission: Run a sample submission to identify potential formatting issues.

How RxTrail Can Help

Submitting error-free data to ESP is essential for maintaining 340B compliance and contract pharmacy pricing. RxTrail Consulting provides expert guidance to:

• Identify and fix data errors before submission 
• Streamline ESP workflows to meet manufacturer deadlines 
• Implement automation tools to prevent common mistakes 
• Train pharmacy and compliance teams on best practices

By working with RxTrail, covered entities can ensure accurate ESP reporting, maintain 340B pricing, and stay ahead of compliance risks. Contact us today to improve your ESP submission process and protect your 340B savings!

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