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Exempt FQHCs from 340B Rebate Pilot

Contact your legislators today!

Over the summer, HRSA announced the creation of a 340B rebate pilot program for a selected group of drugs, with implementation beginning January 1, 2026. According to HRSA’s website, “The Pilot Program will help to inform the development of a process for approving future models that are consistent with the 340B statute and the Administration’s goals.” 

"Under the 340B Rebate Model Pilot Program, covered entities must continue to make purchases through their 340B wholesaler account and must ensure they are only requesting rebates on the above drugs after a purchase is made. These purchases must be made for eligible 340B patients in accordance with the 340B statute. Manufacturers should work with their distributor partners to ensure the WAC price is loaded in the 340B wholesaler account where purchases will be made by covered entities to then obtain a rebate.   Manufacturers should subsequently work with their distributors to obtain necessary data from the 340B wholesaler account to monitor purchases in that account. Covered entities and manufacturers should maintain auditable records for purchases made subject to the 340B Rebate Model Pilot Program. HRSA will continue to audit both covered entities and manufacturers to ensure compliance with statutory requirements. All approved manufacturer plans will issue rebates based at the unit level."
Health Resources and Services Administration

The National Association of Community Health Centers (NACHC) released a comment letter in September calling for FQHCs to be exempt from the rebate pilot, citing concerns that include “significant financial turmoil” and “limits to the range and volume of drugs health centers can afford to stock.” Read the full letter here.

Congressional offices are currently telling us they are not hearing concerns about the 340B Rebate Pilot. Without strong outreach from health centers, lawmakers will assume that the pilot poses no risk to patient access or to FQHC financial stability. Thus, your engagement is what informs legislators that the rebate model is not a technical adjustment; it is a structural change that threatens medication affordability, cashflow, and the core services funded through 340B savings. If legislators do not hear directly from FQHCs, they will not understand the real-world impact of forcing centers to front the full cost of high-cost drugs and wait for rebates that may take weeks or months.

Put simply: if we don’t communicate the consequences, no one else will.

Contact your legislator

More Ways to Act

Empower Your Patients:

Make Civic Engagement a part of Patient Care with Vot-ER!

Virginia Community Healthcare Association has partnered with Vot-ER! Vot-ER provides free, HIPAA-compliant, and nonpartisan tools to help Community Health Centers easily integrate civic engagement into patient care. Over 900 healthcare sites are already using these tools to help their patients get ready to vote and influence policies that directly affect their health.

Explore Vot-ER Tools and Resources:
EHR Integration

Allow patients to check and update their voter registration directly through your patient portals.

Patient Texting

Send nonpartisan election reminders and voting info through your existing texting platforms.

Custom Materials

Access free badges, posters, flyers, and digital resources tailored to your health center.

Contact Bianca!

Interested in getting started? Contact Vot-ER’s Field Director, Bianca Navarro at bianca@vot-er.org, or visit vot-er.org.

Want to contact your member of Congress directly? Quickly identify and contact elected officials including, members of Congress currently representing your health center and community.

Remember, you have the power to make your voice heard by contacting your representatives and advocating for the issues that matter most to you.