The Health Resources and Services Administration (HRSA) has now received more than 1,100 identical public comments supporting 340B rebates tied to a template circulated by Patients Rising, a patient advocacy group that receives pharmaceutical industry funding.
The duplicate comments—which together account for more than 80% of the submissions HRSA has received so far on its 340B rebate request for information (RFI)—contain language closely mirroring Patients Rising template materials. The 1,171 duplicate comments are all attributed to individuals with last names beginning with the letters “A” to “F,” and were largely submitted in alphabetical order from April 1–7.
340B Report first reported on April 7 that more than 100 early submissions to HRSA’s rebate RFI were duplicates tied to a Patients Rising template, based on the 450 comments that the agency had released at the time. Following that report, Patients Rising CEO Terry Wilcox told 340B Report on April 7 that her organization had “stopped any further activity” with the third-party firm it hired to promote participation in the RFI.
In an April 15 follow-up statement, Wilcox again stated that Patients Rising had terminated the outreach effort last week after being contacted by 340B Report. However, she said additional comments continued to process because they had already been queued.
“The day this was brought to my attention, I immediately directed the third-party vendor to stop all activity,” Wilcox said. “At that point, I saw that while 299 comments had posted, additional submissions were already queued in the system and continued to process afterward.”
When asked whether Patients Rising or its vendor had submitted any RFI comments on behalf of individuals without their knowledge or authorization, Wilcox said Patients Rising “was not involved in or aware of how those submissions were handled” by its vendor and “cannot vouch for their specific actions.”
“The vendor explained that an API issue caused them to execute in a way that clearly did not align with our expectations,” Wilcox said.
The flood of identical rebate RFI comments comes as HRSA approaches its April 20 deadline for stakeholders to submit input on whether the agency should move forward with a 340B rebate model. The RFI stated that HRSA “continues to encourage individuals not to submit duplicative comments.”
HRSA issued that RFI on Feb. 16, just days after withdrawing its original rebate pilot following a successful hospital-led legal challenge. The agency released additional documentation on Feb. 23, signaling it was preparing a similar 340B rebate pilot for 2027.
Ties to Pharmaceutical Companies
Patients Rising is a 501(c)(4) nonprofit that is not required to list its donors. However, the group lists 15 pharmaceutical companies as corporate sponsors—including AbbVie, AstraZeneca, Eli Lilly and Johnson & Johnson—as well as the brand-name drug industry’s largest trade group, the Pharmaceutical Research and Manufacturers of America (PhRMA).
The group has repeatedly advocated for 340B policy positions aligned with those sponsors, including supporting a 340B rebate model that provider groups oppose, and advocating against state bills that prohibit manufacturers from placing 340B contract pharmacy restrictions.
Patients Rising’s leadership structure also includes multiple individuals with past and current ties to the pharmaceutical industry. Its board includes Jeffrey Oldham, a former deputy vice president at PhRMA who now leads the Washington, D.C.-based health care consultancy JTO Public Affairs, according to his LinkedIn. His biography on Patients Rising’s website states that JTO Public Affairs “services Fortune 500 and trade association clients across the health care spectrum.”
Patients Rising’s “Executive Advocacy Council,” which the group describes as a “patient- and caregiver-centered governing body,” also includes three former pharmaceutical executives.
One council member, Robyn Peters, previously held senior market access roles at Pfizer and Boehringer Ingelheim before becoming managing partner at the life sciences consulting firm Sapere Health, according to her LinkedIn. She also currently serves on the board of Kalderos, a drug industry technology platform that has lobbied HRSA to use its system for 340B rebates.
Another council member, William Smith, spent a decade as Pfizer’s vice president of public affairs and policy before transitioning to “consulting for major pharmaceutical, biotechnology and medical device companies,” according to his biography. He also works as a senior fellow for the Boston-based free market think tank Pioneer Institute, which has published reports critical of the 340B program—including a webpage on “340B Abuse” funded in part by Pfizer.
Smith’s colleague at the Pioneer Institute, Robert Popovian, also serves on the Patients Rising Executive Advocacy Council. Before joining the Pioneer Institute, Popovian worked at Pfizer on government affairs for more than two decades, according to his LinkedIn.
Popovian repeatedly criticized the 340B program on social media while he worked at Pfizer, including a November 2017 post alleging that “hospitals use 340B program to maximize profits.” After he and Smith left Pfizer and joined the Pioneer Institute, they co-authored a March 2023 opinion piece similarly arguing that the 340B program has “devolved from a program designed to help the poor into a program that generates profits for hospitals, clinics and some for-profit pharmacies.”
Popovian also raised concerns about the 340B program during a September 2025 special hearing on the 340B program before the Kansas Legislature.
Wilcox told 340B Report that Patients Rising’s corporate sponsors did not fund its rebate RFI outreach effort or play any role in developing the templates, adding that she “stand[s] behind the messaging in the templates.”
