by Zion Robinson, Vice President Strategic Programs
September 23, 2025
Imagine paying five times more for drugs upfront—only to wait weeks or months to get that money back. That’s the stark reality facing hospitals under HRSA’s 340B Rebate Model Pilot Program.
Beginning in January 2026, covered entities will no longer see immediate 340B discounts on select drugs. Instead, they’ll carry the full purchase price until manufacturers issue rebates. The regulation may treat this as process, but for hospitals, it’s a cash flow crisis in the making.
The True Cost of Delay in the 340B Rebate Pilot
The Craneware Group analyzed real-world claims from 17 provider organizations—81 covered entities, 573 pharmacies, and nearly 161,000 claims. The findings highlight the scale of the financial risk:
- $430M in wholesale acquisition cost (WAC) pricing reviewed
- $81.7M spent under traditional 340B discounts
- Under rebates? An additional $348.7M in upfront costs
“For providers already under pressure, fronting millions more is not just hard—it’s unsustainable.” – Zion Robinson, Vice President, Strategic Programs
Budgets tighten, programs pause, and frontline teams are left waiting for funds they’ve already earned. Every rebate delay has a downstream effect: on medications stocked, services maintained, and patient access sustained.
The Bigger Shift: Risk Reassigned to Hospitals
This isn’t about paperwork—it’s about who carries the risk.
- Manufacturers win time. They delay payment while holding onto billions in cash.
- Hospitals lose flexibility. They advance resources with no guarantee of speed or predictability in return.
- Communities feel the impact. Any disruption in savings cuts into services that 340B was designed to protect.
For safety-net providers, it’s a dangerous inversion of the program’s intent: shifting the burden from the most resourced actors to those least able to absorb it.
What Needs to Change for 340B Rebate Sustainability
In our formal comments to HRSA, The Craneware Group recommended enforceable guardrails to protect providers:
- Rebate timelines with penalties for delays
- Transparent rules for denials and disputes
- Guardrails on data demands to limit unnecessary administrative burden
- Visibility into pricing so covered entities can validate and reconcile claims
Without these protections, the rebate pilot risks becoming unworkable for hospitals and unsustainable for patient care.
Preparing for 2026: Steps Covered Entities Must Take Now
Waiting until January 2026 is not an option. Providers should act now to build resilience:
- Model cash flow exposure under both discounts and rebates
- Secure data integrity to minimize disputes and audit risks
- Plan for dual systems as discounts and rebates overlap
The 340B Rebate Resource Center: Live Today
The 340B Rebate Resource Center has launched as a proactive lifeline for covered entities. More than a static library, it’s a framework for readiness, offering:
- Plain-language guidance on HRSA’s 340B rebate pilot requirements
- Best practices and checklists for compliance and audit preparation
- Tools to model financial exposure and plan for denials
- Expert insights and advocacy updates from The Craneware Group
At the same time, the platforms providers already rely on—Trisus®, Sentinel®, and Sentrex®—are rebate-ready by design, ensuring covered entities can capture required data, validate it at scale, and generate submission-ready files without bolt-ons or manual rework.
Why This Matters for Patient Access
The rebate pilot is not just a compliance challenge—it is a test of priorities. Will 340B remain a safeguard for patient care, or will it become a financial shell game where providers shoulder the heaviest burden?
2026 is closer than it seems. Providers that prepare now will be best positioned not only to survive the rebate era—but to shape how it unfolds.
The hidden toll of “pay first, care later” is clear: cash flow strain, administrative burden, and risks to patient services. But providers don’t have to face it alone.
The Craneware Group is advocating for accountability, equipping providers with rebate-ready technology, and delivering resources to turn risk into readiness before HRSA’s rules officially take effect.