CCPA has long advocated for thoughtful reforms to strengthen the 340B Drug Pricing Program. Earlier this year, CCPA submitted comments to HRSA expressing support for exploring a rebate-based model to improve transparency and accountability in the program, while preserving its critical role in helping safety-net providers care for vulnerable patients.
Last week, HRSA announced that it will move forward with a revised 340B Rebate Model Pilot Program. CCPA is encouraged by this positive step and will continue to champion further reforms to ensure savings are reaching the patients the program was intended to serve.
What is the 340B Rebate Model?
Since its creation in 1992, the 340B Drug Pricing Program has operated through an upfront discount model, where covered entities purchase eligible outpatient drugs at discounted prices. Over time, however, the program has grown dramatically in both size and complexity, with expanded use of contract pharmacies, increasing vertical integration, and more complex financial arrangements.
Under HRSA’s rebate model pilot, covered entities will receive 340B discounts through a rebate after submitting standardized claims data. The pilot is limited to certain medications selected under the Medicare Drug Price Negotiation Program (currently 25) and is intended to evaluate whether a rebate approach can improve oversight while ensuring covered entities continue to receive the full value of the 340B discount.
Why CCPA Supports Exploring a Rebate Model
Rather than changing who is eligible for 340B or reducing the value of the discount, the pilot changes how the discount is delivered. Because the discount is tied to verified claims data rather than an upfront purchase, the rebate model provides additional transparency that can help strengthen program integrity, reduce opportunities for duplicate discounts, and better inform future policy decisions.
An Important Step, With More Work Ahead
While the rebate model is an important step toward improving transparency and accountability within the 340B program, additional work remains to ensure 340B savings are more directly connected to patient benefit. CCPA looks forward to continuing to work with HRSA, Congress, and other policymakers to advance thoughtful, patient-focused reforms that preserve a critical program.
Visit our issue page to learn more about the 340B Program and CCPA’s ongoing work on the issue at the state and national levels.