CMS says 40 states and Puerto Rico have signed on to the GENEROUS Model, which applies MFN pricing to Medicaid drugs through state-invoiced rebates.
News|Articles|September 25, 2026
FAQ: What Comes Next for the 340B Rebate Pilot
Author(s)Stephen Appezzato
With HRSA's approval window now closed, attention turns to whether health system pharmacies can reconcile rebates at scale before the pilot's Jan. 1 start.
Advertisement
Advertisement
The Health Resources and Services Administration's (HRSA) Sept. 24 deadline to approve manufacturer plans for its revised 340B Rebate Model Pilot Program has passed, leaving roughly three months before approved rebate models take effect on Jan. 1, 2027.1,2 To understand what the shift from upfront discounts to post-purchase rebates means on the ground, Pharmaceutical Commerce spoke with Valerie Bandy, PharmD, vice president of pharmacy solutions at Tecsys, who works closely with hospital and health system pharmacies nationwide. Below are answers to the key questions about the pilot's mechanics, its financial and operational stakes and what stakeholders should prioritize before launch.
Related to this article
Episode 3 of Supply Chain Signal examines the Aug. 31 MFN agreements with nine mid-size manufacturers, the GENEROUS Medicaid model and whether pricing, trade and manufacturing policy now add up to a new pharma operating model.
The White House said Medicaid programs in all 50 states, D.C. and Puerto Rico now receive MFN prices, with nearly $65 billion in savings over a decade.
Rebate delays could force 340B hospitals to pay upfront and wait months for credit, distorting drug spend on the books. Valerie Bandy, PharmD, of Tecsys explains the fallout.
As HRSA's 340B Rebate Model Pilot moves toward its effective date, Valerie Bandy, PharmD, of Tecsys explains what drug-by-drug rebate tracking really demands from hospital and health system pharmacies.
Pharma pricing shifts beyond PBM rebates as Medicare and cash channels reshape launches, WAC cuts and access strategies.
In this week's Pharma Pulse, nine more drugmakers join the MFN program, GoodRx adds a family plan, IPC formalizes its USave partnership, and CSafe expands its thermal cover offerings.
Valerie Bandy of Tecsys on where 340B rebate mechanics threaten pharmacy purchasing, and how stakeholders can prevent disruption.
Advertisement
Advertisement