Expert Tip from Avita Care Solutions

In an ever-changing 340B environment, the 340B Rebate Model Pilot Program will be yet another adjustment for covered entities. When preparing for the potential impact of the 340B rebate model on their missions, covered entities (CEs) must consider how it could affect three core organizational elements: cash flow, 340B administration, and technology. This includes:

Cash Flow Impact

• As a result of the 340B rebate model, CEs will no longer receive the immediate 340B savings offered by the upfront discount model. They will need to purchase medications at Wholesale Acquisition Cost (WAC) and wait for a rebate. This delay in receiving discounts will negatively impact cash flow.
• The covered entity should complete a financial analysis to estimate the new WAC outlay versus the previous 340B costs. This will help leadership prepare should they need to build cash reserves or assess financing options. 

Administrative Impact

• The 340B rebate model requires strict adherence to timelines (claims must be submitted within 45 days of dispensing). Missing these deadlines could result in forfeited rebates.
• CEs should ensure that they have systems in place to submit accurate and timely data to avoid lost rebates.
• CEs should develop internal policies and procedures to escalate manufacturer denials and keep track of pending appeals.
• CEs also should ensure that they have access to the real-time rebate status of a claim and regularly reconcile claims submitted with rebates paid.

Technology Impact

• In adhering to the 340B rebate model, CEs must regularly upload dispensing data on the manufacturer’s designated platform.
• CEs should meet with TPAs to ensure that a process is in place to upload all necessary data in a timely and accurate manner.
• CEs should confirm if they need to integrate new technologies into their existing systems to comply with manufacturer reporting requirements.