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340B rebates in 2027

340B TPA vs. Clearinghouse: Who Should Run Your 340B Rebates?

The 2027 340B rebate model forces a new question for covered entities: should rebate claims run through a separate clearinghouse, or inside the 340B TPA that already qualifies your claims? This page explains what each one does, where the gaps appear, and why Aventi Health, an independent 340B TPA built for the 2027 rebate era, runs rebates inside the same system of record.

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The TPA

What a 340B TPA does

  • Claims qualification

    Determines which pharmacy and medical claims are 340B eligible, using encounter, prescriber and location data from the covered entity.

  • Split billing and contract pharmacy

    Runs split billing for in-house settings and manages contract pharmacy programs, including accumulators and replenishment.

  • System of record and audit trail

    Keeps the eligibility logic and source records behind every 340B claim, so the program can be defended in an audit.

The clearinghouse

What a 340B rebate clearinghouse does

  • Moves claims data

    Receives claims data prepared elsewhere and transmits it to manufacturers or their designated platforms.

  • Formats submissions

    Converts files into the layout a manufacturer or platform expects, often with its own validation rules.

  • Depends on upstream data

    Does not qualify claims itself, so accuracy depends on the TPA, pharmacy or covered entity that supplied the data.

Comparison

340B TPA vs. clearinghouse: side-by-side comparison

Comparison of a 340B TPA and a rebate clearinghouse
Function340B TPARebate clearinghouse
Claims qualification and split billingCore functionNot provided; relies on upstream data
Contract pharmacy and accumulatorsCore functionNot provided
Claims data submission for rebatesCan prepare and submit from the system of recordCore function, using data supplied by others
Rebate reconciliation and denialsMatched against the original qualified claimOften limited to submission status; root cause sits elsewhere
Audit trail / system of recordOne audit trail from eligibility to paymentSeparate records that must be reconciled with the TPA
Specialty pharmacy dataThrough direct pharmacy integrations, where availableOnly what is delivered to it
Who the covered entity works with day to dayOne team for 340B operations and rebatesAn additional vendor and hand-off

See how 340B TPAs compare

The gap

Why a separate clearinghouse adds a reconciliation gap

  • Two sets of records

    Eligibility lives in the TPA; submissions live in the clearinghouse. Every payment, short pay and denial has to be matched across both.

  • Re-keyed or re-exported data

    Claims data is exported, reformatted and re-validated, creating room for unit, NDC or date errors that cause rejections.

  • Slower denial resolution

    When a denial arrives, the documentation needed to dispute it sits in a different system than the one that received it.

  • Missed windows

    Hand-offs add delay against the announced 45-day submission window and make the 10-day pay-or-deny clock harder to monitor.

340B rebate reconciliationHandling 340B rebate denialsRebates across multiple TPAs

One system of record

Running 340B rebates inside your TPA system of record

Aventi Health has 7 years in 340B and serves 300 covered entities, 24 of them hospitals. Rebates run inside the same system of record that qualifies claims, so there is no separate tool, no re-keying and no second vendor to reconcile against. Learn more about Aventi for covered entities and specialty pharmacy rebates.

  1. Step 1: Qualify once

    Claims are qualified in the same system that will submit them, so the eligibility logic and the rebate claim never drift apart.

  2. Step 2: Submit pharmacy and medical claims

    Aventi prepares pharmacy and medical submissions with conforming claim units and submits them to Beacon.

  3. Step 3: Reconcile and resolve denials

    Payments, short pays, denials and aging are tracked against each submitted claim, with one audit trail from eligibility to payment.

  4. Step 4: Include specialty pharmacy

    Specialty pharmacy gateways with BioPlus, Accredo, Optum and many other specialty pharmacies bring specialty data into the same workflow.

2027

Which do covered entities need in 2027?

  • Every covered entity needs accurate claims qualification and an audit-ready system of record—that is the TPA's job.
  • For selected drugs in HRSA-approved manufacturer plans, covered entities need complete, timely claims data submitted for rebates starting January 1, 2027.
  • Covered entities need reconciliation of payments and denials against the claims they submitted.
  • If your TPA can submit and reconcile rebates from its own system of record, a separate clearinghouse is usually an extra hand-off rather than a requirement.
  • Health centers and grantees should confirm their TPA covers every pharmacy relationship, including specialty pharmacies.

340B rebates for FQHCs

FAQ

340B TPA vs. clearinghouse FAQ

No. A 340B TPA (third-party administrator) qualifies claims for 340B eligibility, manages split billing and contract pharmacy programs, and keeps the records that support your program in an audit. A rebate clearinghouse generally moves claims data between covered entities and manufacturers or their platforms. A clearinghouse depends on data that a TPA, pharmacy or the covered entity has already prepared; it does not qualify claims itself.

Not necessarily. A covered entity needs claims qualification, complete claims data submission, and reconciliation of rebate payments and denials. When your TPA prepares and submits rebate claims from its own system of record, a separate clearinghouse is not required. Using both adds a hand-off between systems that someone has to reconcile.

Under the announced 2027 340B Rebate Model Pilot, covered entities are responsible for submitting claims data for selected drugs from HRSA-approved manufacturer plans, through the manufacturer's designated platform such as Beacon. Covered entities can have a TPA or other vendor prepare and submit that data on their behalf, but the obligation and the rebate belong to the covered entity.

Under the announced pilot rules, manufacturers must pay or deny, with documentation, within 10 calendar days of a complete data submission. A denial must be reviewed against the original claim and eligibility records, corrected or disputed where appropriate, and tracked until resolved. This is far simpler when the denial lands in the same system that qualified and submitted the claim.

Yes, if it has the data connections. Aventi has specialty pharmacy gateways with BioPlus, Accredo, Optum and many other specialty pharmacies, so specialty dispense data flows into the same system of record used for eligibility, split billing, contract pharmacy claims and rebate submissions.

Start early. Inventory your contract pharmacies, split billing sites and specialty pharmacy relationships, request historical claims and eligibility data from your current TPA, and plan a transition date that leaves time to validate qualification logic before rebate submissions begin on January 1, 2027. Aventi supports onboarding and can also prepare rebate claims for covered entities that keep another TPA during a transition.

Related pages

Run 340B rebates in one system of record

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