HRSA RFI on 340B Rebate Model Pilot
Health Resources and Services Administration (HRSA) Is Accepting Comments on a Potential 340B Rebate Model Pilot
Comments are due April 20, 2026. NPS encourages stakeholders to share how a rebate-based approach could affect patient access and safety-net operations.
HRSA is currently accepting public comments on whether and how to implement a potential 340B Rebate Model Pilot Program, with comments due by April 20, 2026. As an organization that works closely with 340B-covered entities, NPS encourages stakeholders to use this opportunity to share practical, real-world feedback on how a rebate-based model could affect patient care, pharmacy operations, and the financial stability of safety-net providers.
The 340B program plays an important role in helping covered entities stretch scarce resources and sustain services for the communities they serve. HRSA’s Request for Information asks stakeholders to comment on operational, financial, and patient access considerations, including administrative burden, systems requirements, payment timing, cash flow, and rebate processing. Those are not abstract issues — they directly affect how providers maintain access to medications and services for vulnerable patients.
A central concern for many providers is the difference between an up-front 340B discount and an after-the-fact rebate model. A rebate structure may require providers to purchase first and recover the 340B benefit later, which can create additional administrative work and cash-flow pressure. HRSA is specifically asking for stakeholder input on these operational realities, and this comment period is the right time for organizations to explain what these changes could mean in practice.
“Any change to 340B has to work operationally in the real world. Moving away from the upfront discount model adds financial pressure and complexity for safety-net providers, and that doesn’t just stay operational, it affects patient access. Covered Entities carry the compliance and the cost, so stakeholder input is critical.”
— Danielle Mathers, Senior Vice President, 340B
How to submit a comment (deadline: April 20, 2026)
HRSA directs comments to the Federal eRulemaking Portal (Regulations.gov) and instructs commenters to reference HHS Docket No. HRSA-2026-03042. HRSA also notes that submitted comments are publicly posted, so commenters should avoid including confidential or sensitive information.
Steps to comment:
Go to Regulations.gov.
Search for HRSA-2026-03042.
Open the docket for the 340B Rebate Model Pilot Program Request for Information.
Click Comment (or Submit a public comment).
In your comment, describe how a rebate-based approach could affect:
patient access to medications and services,
pharmacy or clinic cash flow,
staffing and administrative workload,
systems/reporting requirements,
reimbursement timing and rebate denials or delays.
Include specific examples and supporting facts where possible.
Submit your comment by April 20, 2026.
Why NPS is encouraging stakeholder participation
At NPS, we believe policy and program design decisions are strongest when informed by operational reality and patient impact. HRSA is asking for input, and this is an opportunity for covered entities, pharmacy teams, and partners to provide concrete feedback on what supports sustainable care delivery — and what may create barriers.
We encourage stakeholders to submit comments that are specific, practical, and focused on patient care.
Helpful resources
Federal Register Notice (official HRSA RFI and submission instructions)
Regulations.gov (comment portal)
Optional stakeholder resources:
Article by:
Christopher Broom CPhT, 340B ACE
Director of Financial Analytics & Data Strategy
