Split Billing, WAC Purchasing and Cash Flow Under the Rebate Model

Cash flow is the first question

Throughout our recurring webinars, we ran live polls to see what worries 340B covered entities most. Cash flow and payment timing came out on top, chosen by more than 43% of respondents. For pilot drugs, you pay WAC up front and get the 340B discount back later. For the basics, see our explainer on HRSA’s revised rebate model.

How HRSA addressed it

HRSA designed the 10-day payment deadline to fall before standard wholesaler payment terms, so covered entities should not have to float WAC for long. That only helps if claims go out fast and complete. If a claim comes back incomplete, the 10-day clock starts again.

One purchasing account, at WAC

• Order pilot drugs only through your existing 340B wholesaler account. Manufacturers load WAC there for pilot NDCs.
• Do not order pilot drugs through a WAC-only or GPO account if you want a rebate. HRSA says rebates cannot be requested on GPO or other discounted purchases.
• If a manufacturer has no approved plan, the 340B ceiling price stays loaded in your 340B account.

What changes for split billing and accumulators

HRSA describes the order for replenishment models this way: the dispense comes first from neutral inventory, a WAC purchase in the 340B account then replenishes it, and the rebate is requested after that. For pilot NDCs, your accumulator needs to know a claim is on the rebate path, so it does not replenish as if the 340B price applied.

Your billing price after the rebate

The upfront cost is WAC, but HRSA expects the effective cost to be the 340B ceiling price once the rebate is paid. Manufacturers post quarterly ceiling price files by NDC-11 on Beacon to support Medicaid billing and sliding-fee scales.

Where Aventi fits

Aventi runs split billing, in-house pharmacy and contract pharmacy on one platform. We route pilot claims on a separate path, so they are never replenished as if the 340B price applied. We submit daily, reconcile each payment against the amount owed, and our pricing is contingency-only.