by Chris Boles, Senior Vice President, Growth
October 2, 2025
For decades, the 340B Program has done more than balance budgets. It has helped keep care accessible for patients who might otherwise go without. From rural hospitals to urban safety-net providers, 340B savings support medication access, patient assistance programs, and community health services.
With HRSA’s 340B Rebate Model Pilot Program moving forward, that safety net is entering a new test. Under a rebate approach, covered entities pay the full price upfront and receive reimbursement later from manufacturers. That timing shift creates financial and operational pressure that can affect patient care. To help providers prepare, The Craneware Group created the 340B Rebate Resource Center—a continuously updated hub with insights, checklists, and tools that turn uncertainty into clarity.
What Our Analysis Revealed
We examined the potential implications of a rebate model using data from 17 provider organizations comprising 81 covered entities, 573 pharmacies, and nearly 161,000 prescription claims.
Key findings:
- $430 million in listed Wholesale Acquisition Cost (WAC) pricing reviewed.
- $81.7 million actually paid under the traditional discount model.
- Applied to the same mix, a rebate model would drive roughly 5× higher upfront cash outlay—about $348.7 million more in the short term.
That exposure is not theoretical. A rural hospital may postpone medication purchases during rebate delays. A community health center may scale back assistance programs. A safety-net hospital may reduce uncompensated care. In each case, community access to care is at risk.
“For a rural hospital, even a 30-day rebate delay can mean postponing medication purchases or scaling back patient programs.” — Chris Boles, Senior Vice President, Growth
Our Formal Response to HRSA
In August, The Craneware Group submitted official comments outlining how the rebate model, as drafted, introduces operational and financial risks that could undermine 340B’s purpose. Our recommendations included:
- Continuity of care: Keep 340B pricing visible in wholesaler catalogs and avoid unnecessary limits on contract pharmacy access.
- Financial safeguards: Enforceable rebate timelines, interim payment options, and transparency into manufacturer payment practices.
- Interoperability: Align with existing EHR, revenue cycle, and 340B tools to prevent duplicative work.
- Data minimization: Limit requests to the 11 pharmacy-claim fields referenced by HRSA and standardize formats across manufacturers.
- Accountability: Clear denial reasons, real-time rebate status, and penalties for late payments.
Guiding principle: 340B should continue to serve patients and communities without adding new barriers to care.
What Providers Should Prepare For
- Cash-flow management: Even short rebate lags can strain budgets. Build forecasts and scenario plans now.
- Dual-model operations: Many organizations will manage both upfront discounts and rebate submissions at once, increasing administrative load and compliance risk.
- Data validation at scale: Accuracy across the 11 required pharmacy-claim fields is essential to avoid processing delays and disputes.
How We’re Supporting Providers
Advocacy matters, but providers also need immediate, practical support.
That’s why we created the 340B Rebate Resource Center. It offers:
- Plain-language guidance on HRSA’s pilot and evolving expectations.
- Best practices and checklists for data integrity, cash-flow planning, and audit readiness.
- Tools to model cash exposure, prepare for denials, and operate in a dual-model environment.
- Expert insights, webinars, and thought leadership that make complex issues actionable.
- Ongoing advocacy updates so teams know what is changing and how to respond.
Think of it as a single place to coordinate rebate readiness and stay ahead of 2026.
And because preparation shouldn’t wait, platforms many providers already use—Trisus®, Sentinel®, and Sentrex®—support rebate readiness today. They capture the 11 HRSA-referenced fields, validate them at scale, and generate submission-ready files to help reduce manual rework. (Capabilities depend on configuration and active accounts.)
Looking Ahead
The rebate model is not just a new rule; it is a new operating reality. HRSA has indicated January 1, 2026, as the target start date for approved manufacturer plans. Providers should expect to function in a world with both upfront discounts and delayed rebates.
With the 340B Rebate Resource Center, The Craneware Group provides tools, insight, and strategies so organizations can:
- Protect operating cash flow during reimbursement delays.
- Defend against denials with data-driven documentation.
- Navigate new requirements with confidence, backed by technology built for compliance.
- Stay engaged with advocacy so provider concerns are heard at the federal level.
The pilot may test the limits of 340B, but it does not have to test the limits of your organization. With foresight, built-in readiness, and a partner focused on providers, you can move into 2026 with confidence.
The Craneware Group will continue to advocate, equip, and support—so hospitals and health systems can focus on what matters most: delivering care in the communities that depend on them.