AHPA submitted comments on: Request for Information: 340B Rebate Model Pilot Program (HRSA–2026–03042).

Click here for the full comment letter. Below are some key takeaways.

• Preserve the upfront 340B discount model.
  AHPA strongly urges HRSA to retain the longstanding upfront discount structure, arguing that a retrospective rebate model would fundamentally restructure the program and shift financial risk from manufacturers to covered entities. AHPA also raises legal concerns about whether HRSA has the statutory authority to implement such a change without clear congressional authorization.
• Protect hospitals from cash-flow disruptions and financial uncertainty.
  AHPA warns that a rebate model would require covered entities to purchase medications at higher prices and wait weeks or months to recover the 340B discount. This would tie up millions of dollars in working capital, create uncertainty around delayed or denied rebates, and place significant financial pressure on hospitals serving rural, underserved, and socioeconomically challenged communities.
• Avoid imposing substantial administrative and operational burdens on covered entities.
  AHPA emphasizes that hospitals’ current inventory, compliance, auditing, and vendor systems were built around upfront discounts. Moving to rebates would require new claims-submission workflows, additional personnel, greater reliance on third-party administrators, ongoing payment reconciliation, appeals processes, and expanded compliance documentation, all of which would divert resources away from patient care.
• Address the model’s significant technology and data infrastructure challenges.
  AHPA cautions that hospitals would need to develop new connections among electronic health records, pharmacy systems, claims platforms, and outside vendors. It also notes that some necessary claims information is not available in a single system, increasing the likelihood of manual work, data errors, submission delays, and rebate denials.
• Pursue less disruptive alternatives that protect patient-care resources.
  AHPA recommends using neutral third-party clearinghouses for eligible Inflation Reduction Act-selected drugs, improving existing Medicare Drug Price Negotiation Program processes, and developing standardized data-sharing frameworks. AHPA believes these alternatives could strengthen claims verification, prevent duplicate discounts, and improve transparency without jeopardizing the 340B savings used for specialty medications, uncompensated care, chronic disease management, and community health programs.