Webinar

Summary:

In our August webinar, we outlined the framework of HRSA’s 340B Rebate Model Pilot Program and its potential impact on covered entities. Since then, HRSA has released a set of FAQs that provide additional detail but also raise new questions.

Program leaders are now weighing issues such as:

• Which prescriptions are specifically included in the pilot—is it only retail prescriptions?
• How to identify participating manufacturers and understand their data requirements
• Whether non-rebate drugs will continue to be available at the upfront 340B discount
• How reconciliation will function in practice, and what protections exist if rebates are delayed
• The implications for ordering processes, reporting obligations, and Medicaid billing

This session builds directly on our August discussion, moving from the broad program overview into the operational specifics. We’ll examine where HRSA has provided clarity, highlight areas that remain ambiguous, and outline practical considerations to help your team prepare for January 2026.

If August was about understanding the program’s design, this webinar is about addressing the implementation details.