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The Truzo Migration Checklist for Covered Entities

This retained reference has not been revalidated as current policy. Confirm the manufacturer notice, effective date, affected products and state exceptions before acting. See the policy source explorer.

Kalderos's Truzo platform is displacing 340B ESP for a growing list of manufacturers. Miss a re-registration and you can lose pricing. Use this step-by-step checklist to stay ahead of every 45-day window.

For most of the manufacturer-restriction era, one platform mattered: 340B ESP. That is changing. Kalderos's Truzo platform is now displacing ESP for a growing list of manufacturers, and entities registered only in ESP can lose 340B pricing simply by not re-registering in time. This checklist keeps you ahead of it.

Why the migration matters

340B ESP, operated by Second Sight Solutions, was the default channel manufacturers used to collect contract-pharmacy claims data. Truzo, built by Kalderos, is the newer platform, and several manufacturers have moved their data-collection requirements to it. Including Organon, Alkermes, Puma, and Gilead, with more expected to follow.

The risk is quiet and specific: an entity that did everything right in ESP can still lose pricing for a Truzo-migrated manufacturer because a separate registration is required. There is no automatic transfer.

The migration checklist

  1. List your manufacturers. Pull a list of every manufacturer whose products you purchase under 340B. Cross-reference the current platform landscape using the Manufacturer Policy Explorer.
  2. Flag the Truzo-migrated manufacturers. Identify which of your manufacturers now collect data through Truzo rather than ESP (Organon, Alkermes, Puma, and Gilead as of mid-2026, plus any newly announced).
  3. Confirm your ESP registration is still current for manufacturers that remain on ESP. Do not de-register from ESP prematurely; most entities will run both platforms in parallel for the foreseeable future.
  4. Register your entity in Truzo. Create the organization account, verify your OPAIS-linked identifiers, and add each affected site.
  5. Map contract pharmacies and dispensing sites inside Truzo exactly as they appear in OPAIS. Mismatches between OPAIS and platform records are a common cause of rejected submissions.
  6. Assign an owner and a calendar. Submission windows run about 45 days. Put every window on a recurring calendar with a named responsible person and a backup.
  7. Run a test submission where possible to confirm the data format and account linkage before a live deadline.
  8. Document everything. Keep dated screenshots of registrations and confirmations. If pricing is ever disrupted, this record is your fastest route to resolution.

Common failure points

  • Assuming ESP covers everything. The single most expensive mistake. a Truzo-migrated manufacturer will not see ESP submissions.
  • OPAIS mismatches. If your site or contract-pharmacy records in OPAIS are stale, Truzo registration and submissions can fail validation. Because incorrect OPAIS records drive about 75% of adverse HRSA findings, this hygiene pays off twice.
  • No named owner. Platform work falls through the cracks when it belongs to "whoever has time." A 45-day window with no owner is a missed window.

Where this fits

Platform registration and submission management is exactly the kind of recurring operational work that quietly erodes savings when it slips. It is a core component of program optimization, and for entities that want it fully off their plate, our agent services carry the ongoing OPAIS, ESP, and Truzo work through an individually scoped support arrangement.

Article FAQ

Related questions, answered

Do I need to register in Truzo if I already use 340B ESP?

Yes, for any manufacturer that has migrated to Truzo. ESP and Truzo are separate platforms with no automatic transfer, so an entity registered only in ESP will not have valid submissions for Truzo-migrated manufacturers such as Organon, Alkermes, Puma, and Gilead.

Can I stop using 340B ESP after migrating to Truzo?

Not entirely. Many manufacturers remain on ESP, so most entities run both platforms in parallel. De-registering from ESP prematurely can cost you 340B pricing for the manufacturers still using it.

What happens if I miss a Truzo submission window?

You can lose 340B pricing for that manufacturer until compliance is restored. Submission windows run roughly 45 days, so a missed window has direct financial consequences that are hard to recover retroactively.

Keep your 340B savings intact.

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