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3-MO 3.82% -1bp 6-MO 3.98% +1bp 1-YR 4.04% unch 2-YR 4.23% +1bp 3-YR 4.30% +1bp 5-YR 4.38% +1bp 7-YR 4.52% +1bp 10-YR 4.68% +1bp 20-YR 5.22% +1bp 30-YR 5.21% +1bp 3-MO 3.82% -1bp 6-MO 3.98% +1bp 1-YR 4.04% unch 2-YR 4.23% +1bp 3-YR 4.30% +1bp 5-YR 4.38% +1bp 7-YR 4.52% +1bp 10-YR 4.68% +1bp 20-YR 5.22% +1bp 30-YR 5.21% +1bp 3-MO 3.82% -1bp 6-MO 3.98% +1bp 1-YR 4.04% unch 2-YR 4.23% +1bp 3-YR 4.30% +1bp 5-YR 4.38% +1bp 7-YR 4.52% +1bp 10-YR 4.68% +1bp 20-YR 5.22% +1bp 30-YR 5.21% +1bp 3-MO 3.82% -1bp 6-MO 3.98% +1bp 1-YR 4.04% unch 2-YR 4.23% +1bp 3-YR 4.30% +1bp 5-YR 4.38% +1bp 7-YR 4.52% +1bp 10-YR 4.68% +1bp 20-YR 5.22% +1bp 30-YR 5.21% +1bp 3-MO 3.82% -1bp 6-MO 3.98% +1bp 1-YR 4.04% unch 2-YR 4.23% +1bp 3-YR 4.30% +1bp 5-YR 4.38% +1bp 7-YR 4.52% +1bp 10-YR 4.68% +1bp 20-YR 5.22% +1bp 30-YR 5.21% +1bp 3-MO 3.82% -1bp 6-MO 3.98% +1bp 1-YR 4.04% unch 2-YR 4.23% +1bp 3-YR 4.30% +1bp 5-YR 4.38% +1bp 7-YR 4.52% +1bp 10-YR 4.68% +1bp 20-YR 5.22% +1bp 30-YR 5.21% +1bp
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Friday, July 31, 2026
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340B

On a short list of drugs the 340B discount becomes a rebate, and the hospital pays the undiscounted price first

Money & World
The Editorial Team ·
A close photograph of about a dozen clear glass tubes lying with their open ends towards the camera in a blue plastic crate, lit from above, carrying no label or lettering and with nobody in the frame.
Photo: Jess Loiterton / Pexels

The 340B discount has always been a discount. On a small set of drugs it is about to become a refund.

The Health Resources and Services Administration filed a notice on Friday morning announcing a 340B Rebate Model Pilot Program, under which a qualifying manufacturer may deliver the statutory 340B ceiling price as a rebate paid after the fact rather than as a lower price at purchase. The agency says the statute has always permitted this, and that rebates will be used instead of upfront discounts within the pilot. The notice is effective immediately as published, which is scheduled for Monday.

The programme it touches is large. As of 1 April 2026 it counted 15,249 covered entities and 49,214 associated sites, and it reached $100 billion in purchases at 340B prices in 2025.

The scope is narrow on purpose

The pilot does not cover the 340B catalogue.

It covers only the eleven-digit codes of drugs on the Medicare Drug Price Negotiation Selected Drug List for initial price applicability years 2026 and 2027, regardless of payer or indication, and only while a selected drug's negotiated price is in force. That limit doubles as the invitation list: the call for plans runs only to manufacturers holding one of those drugs. Plans are due to the Office of Pharmacy Affairs by 24 August. Approvals, if any come, arrive by 24 September, for a start on 1 January 2027 and a minimum of one year. No manufacturer may run a plan without approval.

The terms sit on the manufacturer

The rebate is wholesale acquisition cost less the 340B ceiling price on the day the drug is dispensed, paid per unit rather than per package.

Payment is due within 10 calendar days of a completed data submission, and the clock restarts if HRSA's required fields are missing. The manufacturer pays for the IT platform. Covered entities get at least 45 days from dispense to submit, a quarterly price file for every eleven-digit code, and real-time reconciliation. Data requests are capped at an enumerated list of claim fields, purchasing and encounter data are off the table for now, and nothing collected may be aggregated, shared or licensed for any other use.

One clause does more work than the rest. A manufacturer may not deny a rebate over eligibility, diversion, Medicaid duplicate discounts, or a suspicion that too little was bought at wholesale price. Those objections go to HRSA, or into an audit, or into administrative dispute resolution.

The argument the notice has to answer

Commenters told HRSA that paying full price first would strain rural and safety net providers.

The agency does not dispute the mechanism, only the size. It cites an IQVIA analysis putting the interest cost of a rebate model at 0.19 percent for entity-owned pharmacy purchases, no larger than the replenishment model those pharmacies use now, and 0.03 percent for contract pharmacies, staying under 1.2 percent even on unfavourable assumptions. It points to a 2021 study by 3 Axis Advisors reaching a similar conclusion for contract pharmacies. Its own mitigation is the 10-day clock, which it says is meant to land the money before the wholesaler invoice comes due, plus unit-level payment and a 15-day grace window for up to two packages held in inventory at the changeover.

Whether that holds is what the pilot is for.

The document: Department of Health and Human Services, Health Resources and Services Administration, Notice Regarding 340B Rebate Model Pilot Program, FR document 2026-15633, filed for public inspection on 31 July 2026 at 8:45 a.m. Eastern for publication on 3 August 2026, signed by Thomas J. Engels, Administrator. The full public inspection text, roughly 148,000 characters, was downloaded and read here; no fetch-tool summary was relied on, and every date, figure and requirement below was matched against the text. The notice states that it is effective immediately as published unless revised by a future notice, and that it follows the Request for Information published at 91 FR 7287 on 17 February 2026. Scope: the pilot is limited to the NDC-11s of the selected drugs for initial price applicability years 2026 and 2027 on the CMS Medicare Drug Price Negotiation Selected Drug List, regardless of payer or indication, and only during a selected drug's price applicability period, so the call for plans runs only to manufacturers holding such drugs. Timetable: manufacturer plans to 340BPricing@hrsa.gov no later than 24 August 2026; approvals, if any, by 24 September 2026; effective date 1 January 2027; participation for a minimum one-year period; manufacturers may not implement a plan without HHS approval under section 340B(a)(1) of the Public Health Service Act. Plan requirements read off the notice: the manufacturer must bear all costs of the IT platform used for covered entity data submission; plans must allow 90 calendar days notice to covered entities before implementation; covered entities must be able to order the selected drugs through existing distribution mechanisms such as 340B wholesaler accounts with WAC prices loaded; covered entities must be allowed at minimum 45 calendar days from date of dispense to submit data; the platform must provide real-time reconciliation reports; a quarterly 340B price file for each 11-digit NDC must be made available. Rebate terms: the rebate equals wholesale acquisition cost less the 340B ceiling price on the day of dispense; rebates are paid at the unit level; plans must accommodate up to two unreplenished accumulated packages with a 15 calendar day grace period before the effective date; all rebates must be paid, or denied with supporting documentation, within 10 calendar days of a completed data submission, with the clock restarting if a submission is returned for incomplete data; rebates may not be denied on eligibility grounds or over diversion or Medicaid duplicate discount concerns, nor for perceived lack of WAC purchases, and a manufacturer with such concerns must raise them with HRSA and the Office of Pharmacy Affairs or use the statutory audit and administrative dispute resolution mechanisms. Data: requested fields are limited to enumerated pharmacy and medical claim fields, purchasing and encounter data are not to be requested at this time, CASH may be entered for uninsured or cash-paying patients, and data received under the pilot may not be collected, aggregated, shared or licensed for any other purpose. Programme scale, from the notice's background section: as of 1 April 2026 the 340B Program includes 15,249 covered entities and 49,214 associated sites, and reached $100 billion in purchases at discounted 340B pricing in 2025. On cash flow, the notice records commenter concern that covered entities would pay wholesale acquisition cost upfront and wait, and states HRSA's contrary view resting on an IQVIA analysis reporting interest costs of 0.19 percent for entity-owned pharmacy purchases under a rebate model and 0.03 percent for contract pharmacies, remaining under 1.2 percent under unfavourable assumptions, together with a 2021 study by 3 Axis Advisors..

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