Dear Bluesight customers and health care leaders,
Our industry faces yet another moment of unprecedented uncertainty. The proposed 340B Rebate Model pilot, set to launch in January 2026, represents one of the most significant changes to the 340B program since its inception. And now, with the current federal government shutdown impacting operations at HRSA and the Office of Pharmacy Affairs, the October 15th deadline for pilot notifications may be in question. And, as of writing, there has been no update.
I am hearing questions and concerns from our customers: What does this mean for my health system? How do we prepare for changes that may or may not come? We’re asking these questions internally as well and want to ensure we’re prepared to partner with our customers to navigate what’s to come.
What’s Causing 340B Program Uncertainty
The shift from upfront 340B discounts to a rebate model isn’t just a procedural change; it’s a fundamental restructuring of how hospitals manage cash flow and drug procurement. Imagine purchasing medications at wholesale acquisition cost today, only to not receive your 340B savings for potentially weeks. Worse yet, some fear that they may have to wait for a process that arbitrates the rebates on a one-off basis further delaying or denying benefits. For many health systems already operating on thin margins, this gap could create serious financial strain.
Add to this the complexity of choosing between the Maximum Fair Price (MFP) under the Inflation Reduction Act and 340B rebates for those same 10 pilot drugs – a choice that, without the right analytical tools, asks health systems to predict the future and bet their savings on it.
The pending 340B ACCESS Act adds another layer, requiring public reporting on how 340B savings are used. While transparency is crucial for our industry’s credibility, the administrative burden of tracking, documenting, and reporting every dollar saved and spent could overwhelm teams already stretched thin.
Why This Moment Matters to Current and Future Operations
Throughout my career in healthcare technology, I’ve seen how regulatory changes can either strengthen or strain hospital operations. What concerns me most about this rebate model isn’t just the operational complexity – it’s that hospitals can’t properly prepare to address it with incomplete information and shifting timelines.
The current government shutdown exemplifies this challenge perfectly. Will the October 15th deadline hold? Will the January 2026 launch proceed as planned? These aren’t just policy questions; they’re practical concerns that affect hiring decisions, budget allocations, and technology investments you need to make today.
Our Promise to You
At Bluesight, hospital intelligence isn’t just about having data. It’s about having the right systems, workflows, and insights to turn that data into action, to safeguard organizations’ budgets, compliance, and patients. As other vendors rush to market with rebate submission services that charge fees to move your data from Point A to Point B, I want to be clear about our approach.
Simply submitting claims isn’t a strategy. It’s a transaction. The best defense healthcare organizations can employ is a comprehensive program that ensures compliance, preserves savings, and withstands any audit. That can be combined with the transaction, but the transaction alone is insufficient.
In January, we will begin offering a new capability in CostCheck for 340B-covered entities to track any drug purchases eligible under IRA or 340B rebate programs. This is the first step towards working through these changes alongside you and integrating the rebate process into our workflows – as Bluesight will expand this initial capability into a complete end‑to‑end submission and rebate‑tracking solution as we all learn how the program will unfold over the next several months. While the timeline for rebates remains uncertain, we recognize there will likely be hiccups with data submission and – as some organizations have stated – a 10-day reimbursement timeline. Whatever reality ultimately takes shape, we’ll be working diligently to ensure a smooth transition, de-risk your processes, and minimize disputes over qualification or workflow alignment.
Looking ahead, we’re also building 340BCheck into a fully integrated, claims‑based platform that will auto‑ingest EHR and claims data, giving you a clearer picture and more complete ownership of your audit journeys, and allowing you to take full control of your 340B program.
Because this is a rapidly evolving, ever-shifting situation, we will continue to keep a pulse on industry changes and the needs of our customers – so we can continue building the tools, partnerships, and integrations that will be most impactful for your organization. As new information emerges, we’ll share our perspective and outline how our plan will adapt to best support you.
Moving Forward Together
To our current customers: Thank you for trusting us to power your operations during these turbulent times. Your feedback and partnership are invaluable as we continue to build solutions that address current and future problems.
Together, we’ll navigate whatever comes: shutdown delays, rebate models, or any other challenge that emerges.
Thank you for all you do for your patients and communities. We’re honored to support your mission.
With determination and partnership,
P.S. If you’d like to discuss how your organization can prepare for these potential changes, regardless of timeline uncertainty, please reach out to our team. We’re here to help you model scenarios, understand your options, and build resilience into your 340B program.