As the healthcare industry braces for one of the most significant shifts to the 340B program in over a decade, pharmacy teams across the country are navigating uncharted waters.
The upcoming 340B rebate pilot will fundamentally change how covered entities handle certain medications, creating new challenges and considerations for hospital pharmacy operations.
Based on insights from industry experts during our webinar, “How Pharmacy Teams Can Prepare for the 340B Rebate Model Before 2026,” here are five trends pharmacy teams need to understand as they prepare for this transition.
1. Cash Flow Disruption Requires New Financial Strategies
The shift from upfront discounts to a rebate model creates an entirely new financial equation for covered entities.
Starting January 2026, hospitals will purchase the first ten IRA-negotiated drugs at full Wholesale Acquisition Cost (WAC) pricing and wait up to 55 days for rebate payments.
This creates immediate cash flow pressure that organizations need to plan for, especially smaller facilities with limited capital reserves. Financial exposure during this waiting period requires careful planning and potentially new budgeting approaches to maintain operations while significant funds are temporarily tied up awaiting rebates.
2. Decision Complexity Creates a New Purchasing Paradigm
The 340B rebate pilot introduces a fundamentally different decision-making process for pharmacy teams.
For the ten affected drugs in the 340 pilot, leaders must now evaluate:
- Does purchasing at full WAC with an eventual rebate make financial sense?
- Is substituting with alternative options more economical and operationally simpler?
- How will this decision process scale if the pilot expands beyond ten drugs?
The complexity is compounded by the need to constantly reassess these decisions as market conditions change. Pharmacy leaders must establish new frameworks for evaluating total cost of ownership across time, rather than making point-in-time purchasing decisions.
As AJ Rivosecchi, Product Director at Bluesight, pointed out in the webinar: “You’re going to be in that situation where the Apple Watch costs a thousand dollars, but there’s a five hundred dollar rebate. And the Google Watch costs eight hundred dollars, but there’s no rebate.” This new reality forces pharmacy teams to reconsider their purchasing strategy entirely.
3. Compliance Requirements Are Unchanged But More Complex to Execute
While the financial model changes dramatically under the rebate pilot, the fundamental 340B compliance requirements remain exactly the same.
Covered entities still must:
- Prevent duplicate discounts (now potentially duplicate rebates)
- Ensure proper patient eligibility
- Maintain audit trails for every transaction
- Provide defensible documentation
The challenge is to execute these current compliance requirements within a completely different operational model. The carve-in versus carve-out decision becomes even more consequential when managing both state Medicaid refunds and manufacturer rebates simultaneously.
As Lauren Forni, Senior Director of Clinical Strategy, noted:
“Submission alone is not the battlefield. It’s the tracking, matching, auditability, and financial reconciliation where the risk really lives.”
4. “Data Sovereignty” Becomes Essential for Success
An emerging trend in the 340B space is what experts call “data sovereignty” – the need for covered entities to have complete ownership and visibility of their data throughout the entire process.
Under the rebate model, pharmacy teams need unprecedented access to and control over:
- Purchase tracking from point of acquisition
- Claim numbers and identifiers
- Submission status and validation
- Rebate payment reconciliation
Without robust data sovereignty, covered entities risk missing submission deadlines, encountering reconciliation issues, or failing to identify when rebates aren’t properly received. This requires new collaborative relationships between pharmacy departments, IT teams, and finance for a seamless data flow.
5. Dual-System Operations Create Staffing and Training Challenges
Perhaps the most underappreciated trend is the operational complexity of running “dual systems” – managing ten drugs under the rebate model while maintaining traditional processes for everything else.
This split approach creates significant operational friction:
- Staff must be trained on two distinct workflows
- Purchase tracking systems must flag rebate-eligible items
- Submission timelines must be managed alongside regular operations
- Claims must be formatted differently for rebate submission
As AJ Rivosecchi highlighted:
“Any operational change that affects such a small percentage of stuff is some of the hardest to work with… how do you maintain operations where 98% of stuff goes down one path, but the 2% of stuff that goes down this other path is so critical to your operation?”
Moving Forward: Practical Steps for Pharmacy Teams
While the 340B rebate pilot introduces significant complexity, taking a pragmatic approach can help pharmacy teams navigate this transition:
- Assess exposure: Determine how many of the ten affected drugs your organization currently uses, and their financial impact.
- Establish ownership: Define who owns each step of the rebate process, especially for contract pharmacy arrangements.
- Develop tracking mechanisms: Create systems to flag and monitor rebate-eligible purchases.
- Set submission timelines: Establish internal deadlines well before the 45-day submission window closes.
- Build audit defenses: Ensure documentation can trace transactions from point of care through rebate receipt.
The initial pilot impacts only ten drugs, providing an opportunity to develop processes that can scale if the model expands. By proactively addressing these trends, pharmacy teams can minimize disruption while building capabilities for the future state of 340B programs.To learn how Bluesight’s solutions can strengthen your data foundation for the upcoming rebate model transition, visit bluesight.com/340BCheck or contact our team for a personalized demonstration.