America’s Essential Hospitals has requested additional information from the Health Resources & Services Administration (HRSA) on how it intends to implement the upcoming 340B Rebate Model Pilot Program.
The Dec. 1 letter details many outstanding concerns with how participating essential hospitals are likely to be impacted by the rebate model. While America’s Essential Hospitals still contends HRSA is not obligated to authorize and implement rebate models, answers to these questions would eliminate dangerous ambiguities or unconsidered risks from the pilot. The association has also requested a meeting with HRSA officials to discuss them.
HRSA plans to launch the pilot on Jan. 1, 2026, which will require all 340B covered entities to purchase certain 340B drugs at wholesale acquisition cost—rather than with upfront discounts at or below the 340B ceiling price. In a September comment letter, America’s Essential Hospitals strongly opposed the pilot and urged HRSA to stop moving forward with the proposed rule.
Contact Director of Policy Rob Nelb, MPH, at rnelb@essentialhospitals.org or 202.585.0127 with questions.