340B covered entities should carefully review the approved 340B rebate models and the 2026 Medicare Physician Fee Schedule (MPFS) Final Rule provisions on new CMS processes for identifying Medicare Part D claims for 340B drugs.

While the current scope may seem limited or not applicable to certain 340B covered entities, now is the most important time to evaluate the implications of these programs if expanded to all 340B drugs and all 340B covered entities in order to ensure that the concerns of 340B covered entities are appropriately addressed.

340B Rebate Models

As a reminder, although the only drugs currently subject to the 340B rebate models are those that will be subject to the Medicare Part D negotiated prices, the 340B rebate models extend to all 340B covered entity types, all payors and all locations of dispensing/administration of the selected drugs. While the current 340B rebate models are being implemented under a “pilot program,” it is highly likely that 340B rebate models will be expanded to many more drugs in the coming years (possibly even during 2026).

Since the announcement of the approved 340B rebate models, the software platform that will be used for all rebate models approved to-date, Beacon, has released additional information about the implementation of the rebate models and details about operational aspect of the rebate models. All covered entities should familiarize themselves with the Beacon platform and rebate model as soon as possible and should be paying close attention to the [...]

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