WEEKLY UPDATE: 04/16/26
The Connecticut Hospital Association (CHA) continues to voice strong opposition to a 340B Rebate Model Pilot Program, the implementation of which would impose detrimental financial and administrative burdens on hospitals and health systems, hindering their ability to serve vulnerable patients. In response to the federal Health Resources and Services Administration’s (HRSA) Request for Information (RFI) soliciting feedback on a potential rebate model, CHA submitted a comment letter urging HRSA to reject and scrap the concept.
“Restructuring the discount framework (even as a pilot model) to shift away from the longstanding, upfront savings model and instead require hospitals to pursue retrospective manufacturer rebates will destabilize the 340B Program,” CHA’s letter reads in part. “Hospitals today face increasing financial strain due to impending federal policy changes that will impact reimbursement and reduce patient access to health insurance coverage, potentially resulting in a substantial rise in uncompensated care. Transitioning any portion of the 340B Program to a rebate model would further compound these challenges by requiring hospitals, in effect, to extend interest-free loans to manufacturers — costs that have not been budgeted for and that many hospitals cannot absorb while awaiting reimbursement.”
CHA also explained the implementation of a rebate pilot would force hospitals to manage two fundamentally different discount models at the same time and would be extraordinarily resource intensive, “as hospitals would need to contemplate implementing new workflows and processes to track claims, hire more staff, submit rebate requests, reconcile payments, refute potential reimbursement denials, and invest in new information technology systems.”
The proposed rebate model pilot would undermine the purpose of a program that has proven successful for more than 30 years — one that has served as a vital tool for hospitals to stretch scarce federal resources to support low-income, uninsured, rural, and medically at-risk individuals. In Connecticut, savings generated from 340B discounts help hospitals deliver whole-person care, improve health equity, and invest in communities most in need, including by establishing and maintaining a wide range of initiatives that enhance access to essential services and offer free and reduced-cost care. Weakening the program would put services such as free cancer screenings, mobile services, behavioral health treatments, transportation to and from medical appointments, and so much more at risk.
The deadline to submit responses to HRSA’s RFI is Monday, April 20. Click here to read CHA’s full comment letter.
Click here to learn more about the importance of preserving the existing 340B program.
