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For Tribal and Urban Indian health programs

340B TPA for Tribal and Urban Indian health programs

Short answer

Tribal health centers run under a 638 contract or compact and Urban Indian health centers funded through Title V of the Indian Health Care Improvement Act can join 340B as federally qualified health centers. To use 340B through outside pharmacies, a program needs a written contract with each pharmacy, each pharmacy registered in HRSA's OPAIS, and a way to keep 340B drugs away from Medicaid duplicate discounts. A 340B TPA handles the claims qualification, split billing and reporting that make those contract pharmacy arrangements work. Starting January 1, 2027, the HRSA rebate pilot applies to Indian Health Care Providers as well; Tribal and urban Indian groups have asked HRSA for an exemption.[1][3][6][7]

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Eligibility

Which Indian health programs can join 340B

Tribal (638) health centers

Outpatient programs operated by Tribes or Tribal organizations under a contract or compact under the Indian Self-Determination Act (P.L. 93-638). They register for 340B as tribal health centers.[1][10]

Urban Indian health centers

FQHCs owned or leased by Urban Indian organizations that receive grant and contract funding through Title V of the Indian Health Care Improvement Act.[1][9]

IHS-operated facilities

HRSA's list of 340B covered entity types names tribal and urban Indian health centers. It does not list facilities the Indian Health Service runs directly, so check with HRSA's Office of Pharmacy Affairs if your site is IHS-operated.[1][2]

Congress included outpatient programs run by Tribes or Tribal organizations under P.L. 93-638, and by Urban Indian organizations funded under Title V of the Indian Health Care Improvement Act, in the Social Security Act's definition of a federally qualified health center. That is why these programs qualify for 340B as health centers.[1][7]

Contract pharmacy and TPA

Getting 340B savings through outside pharmacies

What HRSA requires

  • A written contract with each pharmacy naming every pharmacy and entity location that will use 340B drugs.[3]
  • Each pharmacy registered and active in 340B OPAIS before it dispenses.[3]
  • Medicaid carved out at contract pharmacies unless a state arrangement is reported to HRSA.[3]
  • Oversight and an independent audit of each contract pharmacy at least once a year.[3]

Where a TPA fits

  • Matches pharmacy claims to your patients, prescribers and sites to decide which qualify.
  • Runs split billing and replenishment so 340B inventory is reordered correctly.
  • Keeps the records you need for HRSA audits, manufacturer audits and your own annual audit.
  • Handles manufacturer claims data requests and 2027 rebate claims. See contract pharmacy setup with a TPA.
2027 rebate pilot

What the rebate pilot means for Indian Health Care Providers

HRSA's 340B Rebate Model Pilot starts January 1, 2027. For pilot drugs, covered entities, including Urban Indian organizations in 340B, pay full price upfront through their 340B wholesaler account and get a rebate from the manufacturer within a 10-day window.[4][6]

Tribal leaders have asked HRSA to exempt all Indian Health Care Providers. In its October 1, 2026 comments, TTAG pointed out that Tribal 340B providers must use their funds to carry out their agreements with the Indian Health Service, and asked for an exemption from the pilot and any permanent rebate model. NCUIH has asked for the same since December 2025.[7][8]

HRSA held a Tribal consultation on September 16, 2026, and took written comments through October 1. Until HRSA announces otherwise, plan as if the pilot applies to you.[6]

Manufacturers can only ask for HRSA's standardized claims fields in the pilot. Purchasing and encounter data aren't permitted.[4][5] Read the 340B rebate model guide.

Checklist

Six steps for a Tribal or urban Indian 340B program

  1. Step 1

    Register during an open window

    Tribal and urban Indian health centers register for 340B from January 1–15, April 1–15, July 1–15 or October 1–15, and start on the first day of the next quarter. HRSA may ask a 638 program for its funding agreement instead of a grant number.[1]

  2. Step 2

    Recertify every year

    Covered entities recertify eligibility annually and must tell HRSA right away about any change in eligibility.[2]

  3. Step 3

    Sign and register each contract pharmacy

    Each pharmacy needs a written contract listing every pharmacy and entity location that will use 340B drugs, and must be active in 340B OPAIS before it dispenses. Registration uses the same quarterly windows, and your Authorizing Official has 15 days to approve it.[3]

  4. Step 4

    Decide how you'll handle Medicaid

    Contract pharmacies must carve Medicaid out unless you have an arrangement with the state Medicaid agency and report it to HRSA. Medicaid and Medicare payment for Indian Health Care Providers uses a methodology set jointly by CMS and IHS, so review this with your billing team.[3][7]

  5. Step 5

    Audit and keep records

    Oversee each contract pharmacy, audit it with an independent firm at least once a year, keep auditable records, and self-disclose any non-compliance to HRSA.[3]

  6. Step 6

    Plan for the 2027 rebate pilot

    For pilot drugs, you'll buy at full price through your 340B wholesaler account, submit claims data, and wait for the rebate. Plan the cash and the claims workflow now.[4][6]

How Aventi helps

An independent 340B TPA for community health programs

Contract pharmacy, done for you

Aventi works with 300 covered entities, 24 of them hospitals. We handle claims qualification, split billing, replenishment and reporting for your contract pharmacies.

Rebates included

The rebate module is included for Aventi TPA clients, so pilot drug claims run through the same platform. See why rebates get denied.

Health center experience

Tribal and urban Indian programs register as health centers. See how rebates work for FQHCs.

Switching is simpler than it looks

Already have a TPA? Read how to switch 340B TPAs or compare TPAs.

Talk to us about your program

Book a 15-minute walkthrough of contract pharmacy and 2027 rebates for Tribal and urban Indian health programs.

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FAQ

340B for Tribal and urban Indian programs: common questions

Yes. Tribal contract or compact health centers operated by Tribes or Tribal organizations under P.L. 93-638, and Urban Indian health centers funded through Title V of the Indian Health Care Improvement Act, are eligible as federally qualified health centers.[1][2]

Yes. Any 340B covered entity may sign written contracts with one or more pharmacies. Each pharmacy must be registered and active in 340B OPAIS before it dispenses 340B drugs, and the entity is responsible for its compliance and an annual independent audit. Some manufacturers set their own contract pharmacy limits, so check each manufacturer's policy.[3]

A TPA reviews contract pharmacy claims against your patient and prescriber data to decide which ones qualify for 340B, manages split billing and replenishment, and produces the reports you need for audits. That work becomes more important when manufacturers ask for claims data and when rebate claims start in 2027.

As announced, yes. NCUIH notes that covered entities, including Urban Indian organizations in 340B, would pay full price upfront for pilot drugs and get a rebate from the manufacturer within a 10-day window. TTAG, the HHS Secretary's Tribal Advisory Committee and NCUIH have asked HRSA to exempt Indian Health Care Providers. HRSA held a Tribal consultation on September 16, 2026, and the pilot is scheduled to start January 1, 2027.[6][7][8]

NCUIH estimates Urban Indian organizations' cash outlay could rise by as much as $342,716.14 a year. It says 25 of the 41 IHS-funded Urban Indian organizations take part in 340B. TTAG cites an analysis that Tribal 340B providers bought $115 million in 340B drugs in 2025.[6][7]

HRSA limits pilot submissions to standardized pharmacy and medical claims fields, and says purchasing data and encounter-level data are not permitted in the pilot at this time.[4][5]

Related pages

Sources

  1. HRSA, Tribal & Urban Indian Health Centers (340B eligibility and registration) — https://www.hrsa.gov/opa/eligibility-and-registration/health-centers/tribal-urban-indian
  2. HRSA, 340B Eligibility — https://www.hrsa.gov/opa/eligibility-and-registration
  3. HRSA, Contract Pharmacy Services — https://www.hrsa.gov/opa/implementation-contract
  4. HRSA, 340B Rebate Model Pilot Program — https://www.hrsa.gov/opa/340b-model-pilot-program
  5. Federal Register, Notice Regarding 340B Rebate Model Pilot Program (Aug. 3, 2026) — https://www.federalregister.gov/documents/2026-08-03/2026-15633/notice-regarding-340b-rebate-model-pilot-program
  6. NCUIH, HRSA to Hold Tribal Consultation on 340B Rebate Model Pilot Program (Sept. 4, 2026) — https://ncuih.org/2026-09-04/hrsa-to-hold-tribal-consultation-on-340b-rebate-model-pilot-program/
  7. CMS Tribal Technical Advisory Group (TTAG), Tribal consultation comments to HRSA on the 340B Rebate Model Pilot (Oct. 1, 2026), via NIHB — https://www.nihb.org/wp-content/uploads/2026/10/TTAG-Letter-Re-Tribal-Consultation-Comments-on-340B-Model-Pilot-Program-10.1.26.pdf
  8. NCUIH, letter to HRSA seeking an exemption for UIOs and Indian Health Care Providers from the pilot (Dec. 17, 2025) — https://ncuih.org/2025-12-17/ncuih-sends-letter-to-hrsa-seeking-exemption-for-uios-and-indian-health-care-providers-from-the-340b-rebate-model-pilot-program/
  9. Indian Health Service, Office of Urban Indian Health Programs — https://www.ihs.gov/urban/
  10. Indian Health Service, Office of Direct Service and Contracting Tribes — https://www.ihs.gov/odsct/

Last updated November 11, 2026. General information, not legal advice.