What Does HRSA’s Revived 340B Rebate Pilot Mean for Covered Entities?
One Minute Matters Video Series
8.26.26
The 340B rebate model pilot was blocked by a federal court, withdrawn by HHS, and widely considered finished. Eight months later, HRSA just brought it back with a broader scope – effective on January 1, 2027.
HRSA has made its intent clear: stakeholder objections about administrative burden and cash flow did not stop the first pilot from being proposed, and they are not stopping this one. David Padalino explains what the revived pilot means for covered entities.
Key takeaways:
- The shift from upfront discounts to post-purchase rebates has real cash flow and operational consequences
- The pilot now covers up to 25 drugs from 13 manufacturers (compared to 10 drugs in the first iteration)
- Manufacturers who want to participate must submit plans to HRSA by August 24, 2026
- Covered entities should be assessing purchasing workflows, claims data infrastructure, pharmacy operations, Medicaid billing, and liquidity now
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