What 340B Rebate Tracking Really Demands From Pharmacies

The Health Resources and Services Administration's (HRSA) revised 340B Rebate Model Pilot Program gives qualifying drug manufacturers a path to deliver the 340B discount as a retroactive rebate rather than the traditional upfront price cut.¹ HRSA has framed the revised pilot against the program's rapid growth, noting that 340B purchases climbed from $53.7 billion in 2022 to more than $100 billion in 2025.² The pilot remains narrow in scope, limited to drugs subject to Medicare's negotiated maximum fair price; manufacturers had until August 24, 2026, to submit rebate plans to HRSA, with approved plans set to take effect January 1, 2027. But for hospital and health system pharmacies, even a limited rollout raises a far bigger operational question: what does drug-by-drug, manufacturer-by-manufacturer rebate tracking actually look like on the ground?

In the first installment of her interview with Pharmaceutical Commerce, Valerie Bandy, PharmD, vice president of pharmacy solutions at Tecsys, breaks that down. As Bandy explains, 340B does not operate in isolation. It is embedded in the daily mechanics of hospital pharmacy and supply chain operations, where purchasing, dispensing and the downstream financial and compliance obligations run across separate systems and timeframes.

Introducing rebates into that environment adds another layer of reconciliation. Pharmacy teams must match individual transactions to the correct NDC, confirm 340B eligibility under a covered entity, provider or patient, and verify that a rebate ultimately lands on the right general ledger line, all while pulling data from ERPs, pharmacy systems, electronic medical records, wholesaler platforms, and third-party administrators that do not always align.

Bandy points to survey data from Tecsys showing that 80% of healthcare professionals lack real-time visibility across care settings, and 75% report gaps in integration between clinical and financial systems. The result is a fragmented-data problem, one that scales quickly for large health systems managing thousands of transactions across multiple hospitals, outpatient sites, and specialty pharmacy operations.

With 340B remaining one of the most heavily audited federal programs, Bandy walks through why manual reconciliation is increasingly untenable at scale, and what better visibility and centralized governance could mean as rebate mechanics expand.

References

1. Health Resources and Services Administration. HRSA announces revised 340B Rebate Model Pilot Program to strengthen care in rural and medically underserved communities. HRSA.gov. July 31, 2026. Accessed September 15, 2026. https://www.hrsa.gov/about/news/press-releases/revised-340b-program-2026
2. Holland & Knight. HRSA's revised 340B Rebate Model Pilot Program. HKLaw.com. August 2026. Accessed September 15, 2026. https://www.hklaw.com/en/insights/publications/2026/08/hrsas-revised-340b-rebate-model-pilot-program