Last Updated: September 14, 2026
There is no such thing as a HRSA-issued "340B MOU agreement number." When a form asks for a 340B MOU agreement number, it is asking for a local contract or grant identifier, not a federal 340B identifier. This is the single most common point of confusion in 340B recertification and audit work, and it costs covered entities weeks of back-and-forth every cycle.
At The Marketing Lab, the team runs 340B program administration for covered entities through RxLeverage, and the same question surfaces in nearly every onboarding: a wholesaler form, a payer credentialing packet, or a state auditor asks for an "agreement number," and the program manager does not know what to hand over.
The 340B Drug Pricing Program is administered by the Health Resources and Services Administration under Section 340B of the Public Health Service Act (hrsa.gov). HRSA's Office of Pharmacy Affairs issues exactly one federal identifier to a covered entity: the 340B ID, a six-digit number recorded in the 340B OPAIS database (340B-Search Covered Entities). The federal 340B ID is the only number HRSA itself assigns to a covered entity. Everything else labeled "agreement number" comes from somewhere else.
That distinction matters because supplying the wrong number on a state or payer form creates a documentation mismatch that surfaces in a HRSA audit. The sections below break down who is asking, what they actually mean, and where the correct number lives.
The requester determines the answer. A state auditor, a wholesaler, and a grantee program officer are each asking for a different document, and treating them as interchangeable is where files fall apart.
| Who Is Asking | What They Mean | Where to Get It |
|---|---|---|
| State DOH/AHCA auditor | State contract number | Florida FACTS contract database, or the agency contract manager |
| Wholesaler or distributor | Account number on the 340B purchase agreement | Wholesaler account setup file or the TPA's account record |
| TPA or payer credentialing form | Contract pharmacy or TPA account number | TPA onboarding documents, not HRSA |
| HRSA audit (OPA) | 340B ID, plus executed MOU and grant documents | 340B OPAIS record and the entity's own files |
| Contract pharmacy counterparty | Executed MOU or PSA contract number | Page one of the executed agreement |
| Section 318 grantee | CDC cooperative agreement number | Notice of Award from the state health department |
One warning that saves real trouble: never supply the 340B OPAIS URL record ID as an agreement number. That string identifies a database record, not a contract, and using it on a state or payer form produces a mismatch that has to be unwound later.
Locating the right number takes about ten minutes once you know which category applies. Work through the steps in order and stop when the requester's category is confirmed.
Eligibility rests on documented status, not on any single number. A covered entity qualifies through a specific federal pathway, and the documents behind the agreement numbers are what prove that pathway during recertification. The number on the form is only as good as the executed agreement sitting behind it.
For Section 318 STD entities, eligibility often rests on in-kind support such as HIV test kits supplied by a state health department. Those entities must hold the grantee's Notice of Award and an executed subrecipient agreement. The agreement has to show the recipient and subrecipient names and addresses, the grant number, the NOFO number, the terms of support, and a funding date range, plus proof the in-kind was purchased with 318 dollars.
| Eligibility Pathway | Document That Proves It | Number It Contains |
|---|---|---|
| Section 318 STD grantee | Notice of Award plus executed subrecipient agreement | CDC cooperative agreement number, NOFO number |
| Section 318 subrecipient | Executed subrecipient agreement with funding date range | Grant number, subrecipient agreement number |
| FQHC | HRSA grant documentation and 340B OPAIS record | 340B ID |
| Ryan White entity | Notice of Award and scope-of-project documents | Grant number |
| State-supported STD program | State DOH/AHCA contract | State contract number in FACTS |
HRSA tightened documentation expectations in its August 2025 and January 2026 information-collection notices (regulations.gov). Single-date in-kind entries and unsigned drafts are the gaps auditors find most often. A funding date range, not a single date, is what the agency now expects to see.
A practical sequencing rule: confirm the eligibility pathway first, then pull the Notice of Award, then confirm the executed subrecipient agreement is signed and dated, then verify the in-kind purchase documentation ties back to 318 dollars. Only after those four steps should the agreement number go on any form.
Every number on the identifier sheet needs a source document behind it. HRSA audit documentation is judged on whether the entity can produce the executed agreement, not on whether someone wrote a number on a form. This is the section most competitors skip: they show you a template, not where the number actually lives inside it.
Most results for this query are static PDF templates. Here is where to look inside a standard MOU or subrecipient agreement:
If the number is not on page one and not on the signature page, the document may predate the current numbering convention. That is a documentation gap, not a missing program.
Keep these documents current and filed by entity, with the number, source document, and date recorded in a single tracking sheet:
A missing number is almost always a documentation problem, not a program problem. When a number cannot be located, identify which category it belongs to and go to the issuing source.
A mismatch caught before submission costs an email. The same mismatch caught during a HRSA audit costs a repayment. The identifier sheet and the quarterly roster reconciliation are the two habits that keep the numbers defensible.
A missing number is almost always a documentation problem, not a program problem. When a number cannot be located, the fastest path is to identify which category it belongs to and go to the issuing source.
A mismatch caught before submission costs an email. The same mismatch caught during a HRSA audit costs a repayment.
No. HRSA issues only the 340B identification number through 340B OPAIS. There is no HRSA MOU agreement number. When a form asks for one, it is almost always a state contract number, a CDC cooperative agreement number for Section 318 grantees, or a wholesaler or TPA account number. Ask the requester which they mean before you type anything into the field, because the wrong entry can flag your file during recertification or an audit.
No, and this is the mistake we see most. The OPAIS record ID is an internal identifier for your covered entity record. It is not a contract number, a grant number, or an agreement number, and supplying it on a payer, wholesaler, or TPA form creates a mismatch that is hard to unwind later. Give the OPAIS record ID only when a form explicitly asks for the OPAIS record ID.
A 340B ID is your covered entity identifier issued by HRSA. A grant number belongs to the federal award that makes you eligible, such as a CDC cooperative agreement for a Section 318 STD grantee or a Ryan White award. Both can appear in the same recertification file, but they serve different purposes. In our experience, the confusion peaks when in-kind support is involved, because the file must show the grantee's Notice of Award and an executed subrecipient agreement with the grant number, NOFO number, and a funding date range.
Section 318 STD entities whose eligibility rests on in-kind support need the grantee's Notice of Award, an executed subrecipient agreement showing recipient and subrecipient names and addresses, the grant number, the NOFO number, terms of support, a funding date range, and proof the in-kind items were purchased with 318 dollars. HRSA tightened this documentation in its August 2025 and January 2026 information-collection notices. Single-date in-kind entries and unsigned drafts are the most common gaps, so start state DOH document requests months before the February recertification window.
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