Association Responds to 340B Rebate Model Information Collection Request

In an April 23 letter to the Health Resources and Services Administration (HRSA), America's Essential Hospitals responded to an information collection request (ICR) on 340B Drug Pricing Program rebate models. The ICR covers the submission of plans from drug manufacturers, data submission from covered entities, and plan efficacy evaluation.

HRSA specifically sought feedback on the necessity and utility of the information collections, the accuracy of the estimated burden, and the use of automated technologies that could reduce the information collection burden. The association expressed grave concerns with HRSA's requests, provided member-supported data on the average burden of rebate participation for covered entities, and highlighted the premature nature of the ICR.

The ICR response is separate from the association's feedback on the request for information on 340B rebate models, which closed on April 20. America's Essential Hospitals estimates rebate model implementation could cost 340B hospitals as much as $4.6 billion in 2027 alone.

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.