340B Contract Pharmacy After the Rebate Pilot

Most of your program stays the same

Only pilot NDCs move to rebates. Everything else keeps the upfront 340B price and your usual replenishment cycle. Nearly all approved plans also keep the manufacturer's existing contract pharmacy policy, and the pilot itself does not remove those restrictions. For the basics, see our explainer on HRSA's revised rebate model.

Four changes for pilot drugs

Replenishment happens at WAC. HRSA describes the order this way: the dispense comes first from neutral inventory, the drug is then replenished with a WAC purchase in your 340B wholesaler account, and then the rebate is requested.

You will have two receivables. The contract pharmacy still pays you its share of the reimbursement, and the manufacturer now pays you a rebate as well. Your net position depends on both arriving.

Every payer is in scope. Pilot drugs come from Medicare's negotiated price list, but the rebate applies regardless of payer. Commercial, Medicare and cash claims for pilot NDCs all follow the rebate path.

MFP adds a settlement step. When a 340B rebate is rejected because the Maximum Fair Price is lower, the MFP refund goes to the pharmacy that filled the prescription. That has to be reconciled with the pharmacy. Note: Manufacturers apply different policies here, so make sure to check policies first.

Will pharmacies keep filling pilot drugs?

That is still an open question. Some commenters on HRSA’s notice warned that chain pharmacies might stop offering 340B pricing on pilot drugs, even temporarily, which could leave patients traveling farther. It has happened before: ahead of the first version of the pilot, Walgreens notified covered entities that it would temporarily carve pilot drugs out of its 340B contract pharmacy claims.

Ask your pharmacy partners directly, and early.

The risk to manage

If a pilot claim is replenished at WAC and the rebate is later denied, someone is left holding that cost. Reversing or absorbing it is messy for both the covered entity and the pharmacy. The way your TPA sequences approval and replenishment decides how exposed you are.

Where Aventi fits

At Aventi, we manage eligible 340B claims through two distinct pathways:

• Rebate pathway, for pilot drugs: we capture claims after the medication has been dispensed and picked up by the patient, or administered where applicable. We submit eligible claims to Beacon and track each one through payment and reconciliation. Purchasing follows HRSA’s rules, with pilot drugs bought at WAC through your 340B wholesaler account.
• Replenishment pathway, for all other 340B drugs: eligible claims follow our regular 340B workflow, where dispensed units accumulate toward replenishment at the 340B price.

By routing pilot claims separately, we make sure they are never replenished as if the 340B price applied.

Aventi is a TPA for contract pharmacy, in-house pharmacy and split billing, and we can submit rebate claims for all of your pharmacies. For the full TPA workload, see why TPAs matter more under the rebate model.