Outlay
WAC
- Paid to the wholesaler on normal terms, for every unit of a selected drug
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White paper · Hospital pharmacy and finance
The 340B rebate model in 2027: a pharmacy-to-finance cash playbook
How to run that receivable so January cash does not surprise anyone.
Short answer: from January 1, 2027, HRSA's Rebate Model Pilot replaces the up-front 340B discount with a rebate on the Medicare-negotiated selected drugs. The hospital pays wholesale acquisition cost first and recovers the difference on a 45-day and 10-day clock. Eligibility does not change; the moment the saving reaches your bank account does.
91 FR 48883 · Aug 3, 2026Selected drugs only · under 5.5% of 340B salesWAC first · rebate = WAC minus ceilingWeekly submission · the biggest lever
Edition
1 · 2026
Focus
340B rebate model
Audience
Pharmacy · Finance
Effective date
Jan 1, 2027
Framework
91 FR 48883
Length
14 min read
Jan 1, 2027effective
Revised 340B Rebate Model Pilot for selected drugs [1]
45days
Calendar days from dispense for a covered entity to submit standardized claims data [1]
10days
Calendar days a manufacturer has to pay or deny after a complete submission [1]
<5.5%of 340B sales
Share of 2025 340B sales HRSA says the pilot's drugs represent [1]
The road to the pilot, from the HRSA notice
For thirty years the discount arrived at the point of purchase. The pilot covers only the NDC-11s of drugs on CMS's selected drug list for 2026 and 2027, under 5.5 percent of 2025 340B sales; the other 94.5 percent stays on up-front discounts [1]. Narrow in drugs does not mean narrow in cash.
- 1Aug 1, 2025First rebate pilot notice (90 FR 36163); nine manufacturers approved by April 2026
- 2Dec 29, 2025District of Maine enjoins the 2025 pilot; vacated February 10, 2026
- 3Feb 17, 2026HRSA request for information draws 2,475 submissions
- 4Aug 3, 2026Revised pilot notice published, 91 FR 48883, effective on publication
- 5Aug 24, 2026Manufacturer plans due; HRSA approvals targeted by September 24, 2026
- 6Jan 1, 2027Rebates begin for selected drugs; 90 days' notice to covered entities first
2025 pilot
Enjoined, then vacated
Revised pilot
Published, plans approved, live
Notice to entities
90 calendar days before implementation: early October 2026 for a January start
First attemptRevised pilotNotice window
| Up-front discount (through 2026) | Rebate pilot (from January 1, 2027) | |
|---|---|---|
| Purchase price | 340B ceiling price or lower | Wholesale acquisition cost on the existing wholesaler account |
| Where the saving sits | In inventory, immediately | In a receivable, after claims data is submitted and accepted |
| Data sent to the manufacturer | None at purchase | Standardized pharmacy or medical claims data within 45 calendar days |
| Timing of the saving | Day of purchase | Within 10 calendar days of a complete submission |
| Dispute route | Audit and ADR | Documented denial, manufacturer pathway, then ADR |
Takeaway
Nothing about 340B eligibility changes. What changes is the moment the saving reaches your bank account, and the paperwork that stands between the two.
CMS selected drugs by initial price applicability year, as listed on the CMS page
| Cohort | Drugs on the CMS list | Status on January 1, 2027 |
|---|---|---|
| 2026 (prices effective Jan 1, 2026) | Eliquis, Enbrel, Farxiga, Imbruvica, Januvia, Jardiance | Remain on the list |
| 2026, deselected | Entresto, Stelara, Xarelto, NovoLog/Fiasp | Removed Jan 1, 2027 |
| 2027 (prices effective Jan 1, 2027) | Austedo and Austedo XR; Breo Ellipta; Calquence; Ibrance; Janumet and Janumet XR; Linzess; Ofev; Otezla and Otezla XR; Ozempic, Rybelsus and Wegovy; Pomalyst; Tradjenta; Trelegy Ellipta; Vraylar; Xifaxan; Xtandi | Enter the list |
Regardless of payerHRSA limits the pilot to those NDC-11s regardless of payer or indication: a Medicaid fill and a commercial fill of the same NDC are both rebate transactions [1]
Build your own listFrom the CMS page and HRSA's approved-plan list, not a vendor's summary [3]
Confirm before Jan 1HRSA said it would approve plans by September 24, 2026 and post pilot information within 30 days of the effective date [1]
One rebate transaction under the pilot, with the deadlines in the HRSA notice
Manufacturer gives 90 calendar days' notice
Before implementation
For a January 1 start that notice lands in early October 2026.
You order through the existing wholesaler account
Day 0
Plans must let covered entities order selected drugs through existing accounts with WAC prices loaded; no new accounts.
Dispense or administer; claim adjudicates with the payer
Day 0
Pharmacy owns the dispense record and the data quality.
Submit standardized claims data
By day 45
- Pharmacy or medical data elements only
- Validated before it leaves; the platform filters to the rebate fields
Manufacturer pays or denies
Submission + 10 days
- Rebate per unit: WAC minus the 340B ceiling price
- Incomplete submission restarts the clock when the data is supplied
Denial path
If denied
Documented basis, manufacturer pathway, HRSA reporting tool, then 340B ADR.
The clocks in the pilot, in calendar days
The 15-day grace is a transition rule for dispenses close to the effective date, up to two unreplenished accumulated packages; HRSA's own example uses a December 16 dispense [1].
Notice before implementationmanufacturer to covered entities
90 days
Claims data submission windowfrom dispense
45 days
Transition grace periodup to two packages
15 days
Manufacturer pay-or-deny windowafter complete submission
10 days
0306090 days
NoticeYour clockGraceTheir clock
Standardized claims data elements in the HRSA notice
HRSA excludes purchasing and encounter-level clinical data and bars manufacturers from asking for patient-level information beyond these fields; if a platform asks for more, that is a dispute, not a requirement [1]. Ask for the platform's real-time reconciliation report on day one.
| Pharmacy claims | Medical claims |
|---|---|
| Date of service | Date of service |
| Date prescribed | Claim number and claim line number |
| Rx number and fill number | Unit of measure and quantity |
| NDC-11 and quantity dispensed | NDC-11 |
| Prescriber ID and service provider ID | Rendering physician ID and service provider ID |
| 340B ID | 340B ID |
| RX BIN and RX PCN | Health plan name, health plan ID and ID qualifier (if available) |
Takeaway
Most 340B denials in a rebate world will be data denials: a missing fill number, an NDC-11 that does not match the purchase, a 340B ID typed from memory. Build the file once, validate it before it leaves, and the 10-day clock works for you.
What finance needs to see: outlay, receivable, collection, exceptions
Under the discount model the saving lowered cost of goods. Under the rebate model every selected drug has an outlay, a receivable and a collection, each with a date.
Receivable
Per NDC, per date
- The rebate due once the claims data is accepted: ceiling-price difference per unit
Collection
Within 10 days
- Manufacturer payment inside 10 calendar days of a complete submission, or a documented denial
Exception queue
Owner and date
- Returned submissions, denials and disputes, each with an owner and an ADR escalation date
| Day | Event | Who acts |
|---|---|---|
| Day 0 | Drug dispensed or administered; claim adjudicated with the payer | Pharmacy |
| Day 0 to 45 | Standardized claims data assembled, validated and submitted to the platform | TPA or 340B team |
| Submission + 10 | Manufacturer pays the rebate or issues a documented denial | Manufacturer |
| Submission + 11 | Rebate cash matched to the receivable; denial routed to the dispute queue | Finance and 340B team |
| Monthly | Reconciliation report from the platform tied to the ledger by NDC and 340B ID | Finance |
Float carried, by submission cadence (illustrative days of WAC outstanding, not dollars)
Two numbers decide the float: how quickly you submit inside the 45-day window, and how often a submission comes back incomplete.
Weekly submission, clean fileabout 1 week to submit + 10 days
about 17 daysa few weeks of float
Monthly batch, clean fileup to 30 days to submit + 10 days
about 40 days
Monthly batch with reworked returns45-day window used + restarted clock
60+ daystwo months or more
0204060 days
WeeklyMonthlyMonthly with rework
Takeaway
Set the submission cadence as a finance policy, not a pharmacy habit. Weekly submission is the single biggest lever on the float.
Four denial types, four routes
A manufacturer must document and report each denied claim with its basis and dispute status [1]. Audits and ADR remain available to both sides; the difference in 2027 is a time-stamped record of every transaction.
Data denial
Fix and resubmit
- A field missing or mismatched; the 10-day clock restarts on the complete submission
Eligibility denial
Manufacturer pathway
- Document the 340B ID and the dispensing record
Late or silent
Log it
- Payment past 10 calendar days with no denial: the transaction HRSA's five percent test is built to catch
Systemic
Escalate
- The same basis across many claims: OPA reporting tool, then prepare the ADR filing
5%
Delay thresholdShare of sampled transactions delayed without justification that lets HRSA remove a manufacturer [1]
5%
Denial thresholdSame test for unjustified denials [1]
10
Days to payOf a complete submission; your sample is the evidence you bring
100%
Denials loggedWith the manufacturer's stated basis, on the day they arrive
Limits HRSA placed on the pilot
| Area | What the notice says |
|---|---|
| Purchasing channel | Existing wholesaler accounts with WAC prices loaded; no new accounts |
| Data | Standardized claims data only; no purchasing records, no encounter-level clinical documentation, no extra patient-level data |
| Platform cost | Manufacturers pay the platform's costs |
| Entity types | Not limited by provider type; HRSA rejected limiting participation to non-hospital or volunteer entities because of selection bias |
| Rebate unit | Processed per unit, not per full package |
| Burden estimate | About $34,320 per entity on average, from $523,345,680 across 15,249 covered entities; your number depends on what your TPA already does for split billing |
Pharmacy to finance, in three blocks
- 1Weeks 1 to 4Selected-drug NDC list, manufacturer notices filed, WAC confirmed with the wholesaler. Done when pharmacy and finance sign the list
- 2Weeks 5 to 8Data element map, test submission, platform reconciliation report received. Done when a test file is accepted without return
- 3Weeks 9 to 12Receivable and dispute ledgers open, cadence in the TPA agreement, January cash re-forecast. Done when the CFO has the float assumption in writing
Pharmacy
NDC tagging, WAC confirmation, dispense data quality
340B program or TPA
File build, validation, submission cadence, denial log
Finance
Receivable, reconciliation, cash forecast, dispute escalation
Compliance
Duplicate discount controls, audit trail, ADR filings
Pharmacy340B or TPAFinanceCompliance
Ten moves between now and the first rebate payment
Tag every selected-drug NDC-11Purchased in the last 12 months, in the pharmacy system and the TPA.
File the manufacturer noticesWhich manufacturers HRSA approved and the 90-day notice date each gave you.
Confirm WAC with the wholesalerLoaded on those NDCs for January 1; the 340B account remains the ordering account.
Map and test the data elementsPharmacy system, EHR and billing system to the HRSA fields; test a file before January.
Write the cadence into the TPA statement of workWeekly, with a named owner.
Open the ledgersRebate receivable by manufacturer; denial and dispute sub-ledger; decide how the ceiling-price difference is valued per unit.
Get the reconciliation reportFrom the platform, reconciled to the ledger monthly.
Build the denial logManufacturer's basis, dispute status, ADR escalation date.
Re-forecast January to March cashShow the CFO the submission-to-payment days you are assuming.
Brief the P&T committeeEligibility rules do not change; inventory accounting and the audit trail do.
Two 2027 changes that meet on the same drug line
A selected drug administered in the outpatient department in 2027 may carry a lower Medicare payment, a rebate receivable instead of an inventory saving, and a 3 percent reduction on the rest of the claim. Model the three together.
| Change | Authority | What moves | When |
|---|---|---|---|
| 340B rebate pilot | HRSA notice, 91 FR 48883 | Discount becomes a rebate on selected drugs; cash timing | January 1, 2027 |
| 340B drug payment | CY2027 OPPS proposed rule | Medicare pays ASP minus 33.4 percent for 340B-acquired drugs; first-year estimate $4.55 billion less in Original Medicare drug payments and $1.15 billion in beneficiary payments [4] | CY2027, if finalized |
| 340B remedy offset | CY2027 OPPS proposed rule | Non-drug OPPS payment reduction rises from 0.5 to 3 percent until $7.8 billion is recouped, estimated CY2029; hospitals enrolled after January 1, 2018 excluded [4] | CY2027, if finalized |
StatusThe CY2027 OPPS and ASC rule is still a proposed rule (CMS-1850-P). CMS expects to finalize it in November 2026. Every CY2027 OPPS figure on this page is the proposed figure; re-check it against the final rule before you book it. Our revenue cycle command center gives rebate submissions and disputes the same named owner and traceable outcome as every denial. Related: the MRF audit checklist, this month's Hospital Cash Cycle and what to outsource first.
Frequently asked questions
Does the 340B rebate pilot apply to hospitals, or only to grantees?
It applies to any covered entity that dispenses or administers a selected drug. HRSA states the pilot is limited by drug, not by provider type, and it rejected suggestions to restrict participation to non-hospital or volunteer entities because of selection bias concerns.
Which drugs move to rebates on January 1, 2027?
The 11-digit NDCs of drugs on CMS's Medicare Drug Price Negotiation selected drug list for initial price applicability years 2026 and 2027, regardless of payer or indication. CMS lists ten 2026 drugs, of which four are shown as deselected effective January 1, 2027, and fifteen 2027 drugs. Check the CMS list and HRSA's approved-plan list for the final set.
How fast must a manufacturer pay a 340B rebate?
Within 10 calendar days of a complete claims data submission. If a submission is returned as incomplete, the clock restarts when the missing data is supplied. HRSA may remove a manufacturer whose sample shows five percent or more of transactions delayed or denied without justification.
How long does a hospital have to submit the claims data?
Up to 45 calendar days from the date of dispense, with limited exceptions. A 15-calendar-day grace period applies around the effective date for up to two unreplenished accumulated packages.
What data do we have to send, and what can we refuse?
Only the standardized pharmacy and medical data elements listed in the notice, such as date of service, NDC-11, quantity, prescriber or rendering physician ID, service provider ID and 340B ID. The notice excludes purchasing records, encounter-level clinical documentation and additional patient-level information, and manufacturers bear the platform cost.
- Federal Register: HRSA Notice Regarding 340B Rebate Model Pilot Program, 91 FR 48883, August 3, 2026
- HRSA Office of Pharmacy Affairs: 340B Rebate Model Pilot Program
- CMS: Medicare Drug Price Negotiation Program, Selected Drugs and Negotiated Prices (initial price applicability years 2026 and 2027)
- CMS fact sheet: CY 2027 Hospital OPPS and ASC Payment System Proposed Rule (CMS-1850-P), July 2, 2026
- Federal Register: CY 2027 OPPS and ASC proposed rule (CMS-1850-P), 91 FR 41733, July 7, 2026
The 15-day grace is a transition rule for dispenses close to the effective date, up to two unreplenished accumulated packages; HRSA's own example uses a December 16 dispense [1].
Entering the 340B rebate pilot in January?
We map the data elements, set the submission cadence and build the receivable and dispute ledger so the rebate arrives on the 10-day clock and finance can see it.