The Health Resources and Services Administration ("HRSA") plans to implement a limited pilot program that will allow approved manufacturers to issue post-purchase rebates for 340B covered outpatient drugs rather than upfront discounts.

On August 1, 2025, HRSA announced it is inviting certain drug manufacturers to apply for participation in a voluntary 340B Rebate Model Pilot Program. Unlike an upfront discount model, where covered entities participating in the 340B program are charged only the discounted price on eligible outpatient drugs, the rebate model that will be the subject of the pilot will effectuate the 340B discount through a post-purchase rebate equal to the difference between the purchase price and the 340B ceiling price (subject to the submission of required data).

The De

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