Issued by The Craneware Group | July 31, 2025
This morning, HRSA issued a pre-announcement of the 340B Rebate Model Pilot Program, which could significantly change how certain 340B drugs are purchased and reimbursed.
Starting January 1, 2026, manufacturers accepted into the pilot will provide post-purchase rebates, rather than upfront 340B discounts, on a select group of drugs.
This marks the first HRSA-sanctioned shift away from traditional 340B discounting and introduces new workflows, timelines, and reporting requirements for affected covered entities.
Key Points for Covered Entities
What's Changing
- Drugs listed under the MDPNP may be shifted from an upfront discount to a post-purchase rebate, pending HRSA approval of manufacturer plans
- Covered entities will pay full price up front, then submit claims data to receive the 340B rebate
When
- Manufacturer applications are due to HRSA by September 15, 2025
- Pilot participation begins January 1, 2026, pending HRSA approval
- HRSA is accepting public comments until August 31, 2025
The Craneware Group Remains Rebate Ready
If you're a customer of The Craneware Group, you're ready, too.
Our solutions are built for data integrity and adaptability. The Craneware Group already collects the 11 pharmacy claim data elements required for rebate submission under the pilot.
You’re well-positioned right now to meet the reporting expectations if any of your manufacturers choose to participate.
We're Advocating on Your Behalf
We will submit formal comments to HRSA that reflect the concerns and priorities of our customers. Protecting the integrity of 340B is our priority.
We also encourage you to share your perspective. Public comments play a vital role in shaping the future of the 340B Program.
Need help? Contact your Customer Partner or reach us at [email protected]
You can read HRSA’s Rebate Notice here.