Association Responds to 340B Rebate Model Request for Information

In an April 20 letter to the Health Resources and Services Administration (HRSA), America's Essential Hospitals responded to a request for information (RFI) on 340B Drug Pricing Program rebate models by sharing real-world member data showing how these models would harm patients.

HRSA requested feedback from 340B stakeholders on how a transition away from up-front discounts would affect providers and the patients who benefit from the program.

The letter urges HRSA to halt further consideration of rebate models and fully evaluate RFI responses before acting further.

The association highlights that:

• 340B hospitals could face between $1.5 billion and $1.6 billion in additional direct operating costs in 2027 due to increased staffing needs, new or modified software and vendor contracts, loss of subceiling discounts, and borrowing to finance upfront drug purchases.
• Total costs associated with rebate model implementation could reach between $3.5 billion and $4.6 billion in 2027 when accounting for rebate denials and wasted products.
• Rebate models threaten essential hospitals' ability to serve the patients the 340B program is intended to support.
• By increasing drug acquisition costs, rebate models heighten the risk of product shortages.
• Rebate models are not necessary to comply with the Medicare Drug Price Negotiation Program (MDPNP); manufacturers and covered entities already are complying with MDPNP requirements in 2026 without them.
  

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