Premier Responds to RFI on Potential 340B Rebate Model Pilot Program

Premier submitted comments in response to HRSA’s Request for Information on a potential 340B Rebate Model Pilot Program, raising concerns that a rebate‑based approach would undermine the program’s core structure and create significant financial and operational risk for hospitals. In its comments Premier:

• Emphasized that the 340B program’s longstanding upfront discount model is critical to helping safety‑net hospitals stretch scarce resources, maintain access to outpatient drugs, and reinvest savings in services for underserved and medically complex patients.
• Warned that replacing upfront discounts with a rebate mechanism would shift costs, cash‑flow risk, and administrative burden onto hospitals already facing tight margins, workforce shortages, and rising drug costs.
• Noted that a rebate model could lead to delayed or denied reimbursement, uncertainty in budgeting, and material liquidity challenges, particularly for rural and safety‑net hospitals with limited reserves.
• Highlighted the substantial systems, staffing, and compliance infrastructure a rebate program would require, diverting ongoing resources away from patient care.
• Raised concerns about inconsistent manufacturer requirements, limited accountability, and the risk of repeating past implementation failures that led to litigation and HRSA’s withdrawal of a previous rebate pilot.
• Cautioned that existing challenges with CMS’ IRA rebate reconciliation platform demonstrate the need to resolve operational and accuracy issues before expanding any rebate‑based approach.

Premier urged HRSA not to proceed with a rebate model that replaces the current upfront discount structure, citing risks to provider financial viability and the reliability of 340B savings. If HRSA moves forward despite these concerns, Premier recommended clear guardrails, including enforceable payment timelines, standardized HRSA‑controlled requirements, efficient dispute resolution, limits on operational complexity, strong data security protections, and transparent public reporting on pilot performance.