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 the340B Drug Pricing Program? 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 LawRORY MARTIN, PHD, IQVIA Market Access Technology Solutions Table of contents Abstract1Introduction2Discount 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 models23About the authors25Acknowledgements25Funding25Conflictsof25 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 forthe predominant drug inventory model used by thosepharmacies, referred to as physical replenishment.For contract pharmacies, the rebate model had lowerinterest costs (0.03%) than both types of replenishmentmodel — physical and credit-based replenishment. Evenunder unfavorable assumptions, rebate interest costsremained under 1.2%. 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 shiftfrom upfront discounts to retrospective rebates. Rebatecritics assert that rebates will be a severe financial burdenon providers due to interest costs associated with cashflow, while rebate advocates contend they will not imposeany significant costs on providers. 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-owned pharmacies are expected to total $11 millionunder the 340B rebate model, or just 0.02% of theircombined list price value ($56.2 billion). 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),credit-based replenishment, and two versions of a340B rebate model. Scenarios spanned entity-ownedpharmacies and contract pharmacies. Sensitivity analysestested extended rebate payment timelines, higherinterest rates, and shorter wholesaler payment terms. These findings suggest that financing costs under the340B rebate model are small and unlikely to be a barrierto its use by covered entities. 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 rebatemodel pilot program.1,2Multiple government reportspreviously have expressed concerns about duplicate340B/Medicaid rebates and diversion in the 340Bprogram.3-6The implementation of price negotiationfor Medicare Part D drugs beginning in January 1,2026 has created another risk of duplicate discounts,because a Medicare negotiated price is not owed wherea lower 340B price is offered.7Due to concern aboutthese additional potential duplicate discounts, HRSA’srebate pilot is focused on the first 10 drugs selected bythe Centers for Medicare & Medicaid Services (CMS),1although the announcement indicates that a rebate modelmay be employed more broadly at a later date. Supporters of the rebate model have been advocatingfor its adoption for more than five years.8In pressing forthe adoption of rebates, its advocates have pointed to thefact that the Public Health Service Act repeatedly refersto both “rebates” and “discounts” as permissible paymentmechanisms.9Furthermore, the rebate model may requirecovered entities to implement more robust practicesfor data integrity, inventory tracking, and eligibilityverification, standards that more closely align with therules used to manage drugs outside of the 340B program. which contend that this position is inconsistent with theplain language of the statute, appealed those decisions.11 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 “risksimposing additional costs and burdens on providers.”That argument appeared to resonate with at least oneof the judges hearing the case who asked if a rebatemodel would require providers “to give interest-freeloans to manufacturers.”12A d