返佣模式将如何影响340B药品定价计划中的现金流？

How Will a Rebate ModelImpact Cash Flow in the CHUAN SUN, MS, MA, IQVIA Market Access Technology SolutionsSHANYUE ZENG, MA, IQVIA Market Access Technology SolutionsWILLIAM SARRAILLE, JD, University of Maryland Francis King Carey School of Law Table of contentsAbstract1Introduction2Discount mechanisms in the 340B program3340B rebate model pilot4ADAPs and rebates4The importance to patients of upfront discounts versus rebates4The importance to manufacturers of upfront discounts versus rebates4340B drug inventory and pricing models4Study aims7Data and methods8Data8Methods9Limitations9Findings10Cash balance graphs10Interest costs12Interest costs for the 10 IPAY 2025 drugs13Sensitivity analysis14Interest rate, 340B discount, and WAC14Rebate timeline14Wholesaler payment timeline14Discussion17References19AppendixA:22Appendix B: Descriptions of the eight 340B drug inventory and rebate models23 About the authorsAcknowledgementsFundingConflicts 25 reimbursement value of the 340B program — expressedas a percentage of wholesale acquisition cost (WAC).For entity-owned pharmacy purchases, interest costsfor the rebate model (0.19%) were no larger than for Abstract On October 30, 2025, the Health Resources andServices Administration (HRSA) approved plans for eightmanufacturers to participate in a rebate pilot for the 340BDrug Pricing Program (“340B Program”), signaling a shift Using 2023 data for the 10 drugs selected for bothMedicare Part D price negotiation and the 340B rebatepilot in 2026, the estimated interest costs at entity- We developed data-driven cash flow models to estimatefinancing (interest) costs under eight drug inventory andrebate scenarios including physical inventory, physicalreplenishment (also known as virtual replenishment), These findings suggest that financing costs under the340B rebate model are small and unlikely to be a barrier Across all eight scenarios, financing costs were small— less than half of one percent of the estimated Introduction The Health Resources and Services Administration (HRSA)recently announced its intent to implement a 340B rebate model pilot program.1,2Multiple government reportspreviously have expressed concerns about duplicate 340B/Medicaid rebates and diversion in the 340Bprogram.3-6The implementation of price negotiation for Medicare Part D drugs beginning in January 1,2026 has created another risk of duplicate discounts, Supporters of the rebate model have been advocating which contend that this position is inconsistent with theplain language of the statute, appealed those decisions. for its adoption for more than five years.8In pressing forthe adoption of rebates, its advocates have pointed to the fact that the Public Health Service Act repeatedly refersto both “rebates” and “discounts” as permissible payment An appellate panel recently heard those manufacturerappeals. At oral argument, counsel for the governmentasserted that HRSA’s failure to adopt a broad rebatemodel was appropriate because that model “risks imposing additional costs and burdens on providers.”That argument appeared to resonate with at least oneof the judges hearing the case who asked if a rebate model would require providers “to give interest-free Opponents of the rebate model, however, have arguedthat the statute did not permit this payment mechanism loans to manufacturers.”12A decision is expected under any circumstances. Although that position hasnow been rejected by two district courts, those courtshave held that HRSA has the authority to pre-approve to 340B hospitals and clinics, and that rebates would“improve integrity and transparency within the 340B The financial impact of 340B rebates on covered entitycash flow has been studied under various scenarios involving contract pharmacy transactions.19Based on theassumptions made, that study concluded that a rebate In the litigation over the rebate model, the primarysupport offered for the contention that rebates would financially burden 340B covered entities is a reportbased on a member impact survey that was conductedby a 340B hospital advocacy group.16, 17This report Given the sharply divergent views expressed about therebate model, the cash flow consequences of a shift fromupfront discounts to rebates warrant empirical evaluation. This seems particularly true because the 340B programreached $147.8 billion in sales at WAC in 2024 and grew This member survey has been criticized by some.18The survey instrument used was not disclosed, so it is notpossible to assess potential bias that it might reflect. Discount mechanisms in the 340B program During the life of the 340B program, two mechanismshave been used to deliver lower cost drugs — upfrontdiscounts and rebates. With an upfront discount, the340B hospital or clinic pays a reduced price at the time ofpurchase, lowering its initial acquisition cost. In contrast,under a rebate model, the covered entity initially pays a In addition, the survey was based on the assum