340B返佣是否给340B提供商带来了巨大的财务负担？

Do 340B Rebates Create aSignificant Financial Burden for340B Providers? RORY MARTIN,PHD, IQVIA Market Access Technology SolutionsCHUAN SUN,MS, MA, IQVIA Market Access Technology SolutionsWILLIAM A. SARRAILLE,JD, University of Maryland Francis King Carey School of Law Table of contents Abstract1Introduction2Listprice 3Paymentterms3Data and methods4Data4Methods4Limitations5Findings5Discussion8References10About the authors11Acknowledgements11 Abstract In 2025, the Health Resources and ServicesAdministration (HRSA) proposed transitioning the 340BDrug Pricing Program (“340B program”) to a rebatemodel. While 340B hospitals and others expressedconcerns, some patient advocates and covered entitytypes already using a rebate model expressed support.A court enjoined (prohibited via an injunction) thepilot after crediting 340B provider trade associationrepresentations that purchasing drugs at list price andreceiving a 340B rebate at a later date would impose asevere financial burden on them. 340B providers. We divide covered entities into threegroups based on financial liquidity and assumed short-term borrowing rates. Interest costs are estimatedoverall and per covered entity for the 10 drugs subject toMaximum Fair Price (MFP) in 2026. Using January 2026 list prices for the 10 MFP drugs,estimated annual interest costs per covered entityranged from $590 for federal grantees to $23,649 forDisproportionate Share (DSH) hospitals, versus estimatedpurchases of $86,294 and $6.9 million, respectively. Theseinterest costs represent less than 1% of combined 340Bpurchases for these drugs at list prices. We decided to examine the claims made in the litigation.Significantly, 5 of the 10 drugs that would have beensubject to the 340B rebate pilot subsequently reducedtheir list prices, potentially reducing interest costsassociated with the use of 340B rebates. This data-drivenstudy evaluates whether a rebate-based purchasingmodel would impose a meaningful financial burden on Consistent with, and extending, our earlier study of340B rebate cash flow, these findings indicate thatinterest costs under a 340B rebate model are marginaland inconsistent with claims that a rebate model wouldimpose a significant financial burden on 340B providers. Introduction On January 1, 2026, two important federal drug pricingpolicies — Maximum Fair Price (MFP) and the proposed340B rebate pilot — were scheduled to go into effectinvolving the same set of 10 drugs. However, while MFPrebates were implemented, the 340B rebate pilot wasnot. Although HRSA first announced a 340B rebate piloton August 1, 2025,1and approved it on October 30,2025,2the 340B rebate model was the subject of a legalchallenge brought by the American Hospital Association(AHA) and others and enjoined by the United StatesDistrict Court for the District of Vermont on the eve ofthe January 1, 2026 implementation date.3 Many parties, including the court, have asserted that,under a 340B rebate model, the provider orders druginventory, pays for it, and only thereafter receives arebate payment, generating negative cash flow and,therefore, interest costs. This depiction contends thatwhen inventory is ordered and when payment to thewholesaler is due are essentially concurrent. In practice,however, there is typically a lag between the two events,with timing between the point at which the product isdelivered and paid for determined by a set of contractualprovisions known as “payment terms”. Depending onthese terms, receipt of the rebate may precede, coincidewith, or follow payment for the drug. In their complaint to block the 340B rebate model, theplaintiffs highlighted their contention that requiringthem to pay a commercial price for a drug and thensecure a rebate payment would “inflict hundreds ofmillions of dollars” of costs on hospitals and other 340Bproviders.3The complaint described those costs as“crushing”, “enormous”, “and calamitous”,4but plaintiffsprovided no data to support these allegations. To estimate the true interest cost of 340B rebates, wepreviously created a data-driven cash flow model7basedon a set of parameters including the drug’s wholesaleacquisition cost (WAC, also known as list price), its 340Bdiscount price, and its reimbursed price, wholesalerpayment terms, short-term borrowing rates, and thetiming of the 340B rebate payment. Contrary to theassertions made in the district court litigation, we foundthat interest costs were small, typically less than 1% of thedrug’s list price, and were the same or less for the 340Brebate model than for existing drug inventory models thatuse upfront discounts to effectuate the 340B discount. A group of trade association amici curiae (“friends of thecourt”) filed a brief in support of the plaintiffs’ position.Citing an earlier survey of a non-randomized groupof approximately 3% of all covered entities, the briefasserted that the average “float” cost to a 340B hospitalwould be $8.6 million a year.5The results of the surveystated th