Expert Tip from AuthorityRx

HRSA’s recent announcement of a 340B rebate model pilot is stirring conversation—but don’t mistake it as the final destination. While the pilot introduces limited data requirements for the model pilot, it’s only a preview of what I expect to come.

While we await HRSA’s comment period to elapse, there could be changes to the required data elements. The initial data requirements that HRSA issued did not adequately explain how to handle the proposed piloted drugs when administered in a clinic setting. We know that manufacturers want more than just pharmacy data but also patient and purchasing data. Their push for more data elements means the complete data set will be essential in the long run. That’s why it’s critical to pay close attention and continually prepare for the possibility of a full rebate model!

Stay proactive: Ask your data partners to demonstrate their ability to submit all required data elements—not just those in the pilot. This ensures you’re ready if a full model rolls out.

Reference:  Back in May, I submitted the 340B Report Industry Insights article “Should We Prepare for a 340B Rebate Model?” Check it out; it is imperative to be ready.