CAHC submitted comments to the Health Resources and Services Administration (HRSA) in response to a request for information on the 340B Rebate Model Pilot Program.
In the comments, CAHC applauds HRSA for exploring steps to improve the 340B program, including through a rebate model, and encourage HRSA to move away from a discount approach to facilitate lower cost drugs for patients and to better stretch resources for entities that serve low-income populations.
Today’s comments build on a September 2025 comment letter regarding the pilot, where we highlighted concerns regarding the unchecked expansion of the 340B program, persistent rebate duplication, and the growing complexity caused by the Inflation Reduction Act (IRA). They also emphasize how a rebate-based model can address program inefficiencies, including misallocated resources, which are key drivers of higher costs for patients.
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