With the 340B program putting significant pharmacy dollars at risk, teams must look for ways to lower drug costs, grow reimbursement, and track rebate payments – all while staying 340B compliant. But most are not prepared to face all of these challenges at once.
Unfortunately, purchasing, rebate tracking, and compliance are often managed by separate teams, on separate timelines, with separate data sets – all relying on manual processes.
The problems converging on January 2027
The rebate model puts additional pharmacy dollars at risk
The 340B rebate pilot (now planned for January 1, 2027) converts the upfront 340B discount to a retrospective rebate on applicable drugs. Combined with MFP refunds, this means health systems will pay full WAC price upfront and wait up to 55 days to recover what they’re owed – putting a significant amount of capital at risk if not tracked effectively. Based on our data, the average health system will have $760k in cash tied up in 340B rebates next year – with only a subset of drugs being included in the program.
The model also creates operational jobs nobody owns today: chase every rebate before its window closes, prevent duplicate claims across two programs, and maintain a defensible record for every dollar claimed so you can answer denials, clawbacks, and GFIs. These aren’t pharmacy, compliance, or finance jobs in isolation. They sit at the intersection of all three – which is exactly where most health systems have the least visibility. HRSA estimates the rebate model adds more than $34,000 per facility per year in administrative burden alone – but many organizations estimate their costs could be in the millions.
Margin compression is arriving faster than most teams can adapt
As care continues shifting into outpatient settings, new payment policies are expected to reduce 2027 outpatient payments by $290 million. Pharmacy is increasingly tasked with margin protection and revenue growth within the health system – expected to function as a revenue center at exactly the moment that revenue recovery is hardest to realize.
Pharmacy and revenue cycle teams work from their own data, so in most cases, the net dollar result of any purchase decision stays invisible until it’s too late to act.
340B compliance can’t scale on manual processes
Sample-based self-audits cover less than 5% of 340B transactions, leaving the vast majority of a covered entity’s program without meaningful oversight. As organizations expand services, add contract pharmacies, and see transaction volumes rise, the likelihood of missed errors, compliance risk, and unrealized savings rises with them.
HRSA requires transaction-level records across multiple sources to demonstrate compliance and maintain OPAIS accuracy – and that requirement only gets harder to meet as the rebate model adds new layers of documentation to the equation.
How Bluesight is helping partners navigate changes
For 340B covered entities, Bluesight is already a registered TPSE, connected to Beacon, and actively building the claims infrastructure the rebate model requires.
And to lower drug costs, grow revenue, and stay audit-ready, we connect what you buy, what you’re paid, and the documentation needed to defend against an audit. Unlike point solutions that focus on spend reduction, prior auth, or 340B rebate alone, Bluesight tracks and protects every dollar from purchase to rebate.
- On the cost, revenue, and rebate side, CostCheck can identify lower-cost drug options and highlight revenue opportunities by showing which medications will drive higher reimbursement – based on actual reimbursement rates. We also identify overcharges, catch contract errors, and model the optimal purchase path for each drug at each site across 340B, MFP, and WAC options. When the rebate arrives, our solution ties it back to the original invoice, showing what’s been paid, what’s outstanding, and the true net cost of ownership for every drug.
- On the 340B compliance side, 340BCheck audits every 340B transaction – not just a sample, syncs with OPAIS daily, and keeps all program documentation current so errors get fixed before HRSA finds them. It surfaces only the transactions, records, and documents that require human review, so the program can grow without adding headcount. When the rebate pilot goes live, the solution will confirm eligibility before submitting each claim, track submission and payment status, prevent duplicate claims across the 340B and MFP programs, and keep the record that lets you respond to any denial or clawback.
Our solutions solve the 340B rebate problem end to end: identifying every eligible transaction, submitting the data, and tracking each rebate dollar. For pharmacy, finance, and procurement teams, this means lower costs, more revenue, and continuous compliance, without the manual burden that’s been holding programs back. And the proof is already visible: every health system using CostCheck has saved 1–9% of annual drug spend, with $3M or more in new revenue opportunity identified. And zero of our 340BCheck customers audited by HRSA have received any adverse findings.
The rebate model is going to fundamentally shift your financial liquidity next year. We’re here to help minimize your risk. Fill out the form below to speak with our team today.