340B Unscripted

In this episode, Greg and Rob catch up on more recent developments across the 340B community. They discuss recent Congressional activity where 340B has been a focus, a shift in court rulings related to state contract pharmacy laws, and they catch up on recent litigation over 340B child site eligibility timing, GPO Prohibition policies, and patient definition. They round out the discussion by recapping developments with manufacturer...

In this episode, Greg and Rob discuss reports of 340B pricing removal from wholesaler accounts, which may be related to recent manufacturer claim submission requirement policies.  They also catch up on some developments in state-level contract pharmacy laws, including Washington’s newly passed state law that incorporates contract pharmacy provisions, as well as reporting requirements for both providers and manufacturers.

In this episode, Greg and Rob are joined by returning guest, healthcare attorney Jeff Davis. They’ll be discussing the CMS provider-based rule changes coming out of the 2026 Consolidated Appropriations Act, including the impact that these changes will have on 340B hospitals. They’ll also share some initial reactions to the Albany Medical Health System v. HHS court ruling out of the DC District Court, which has resu...

In this episode, Greg and Rob are joined again by healthcare attorney Todd Nova to discuss the recent HRSA Request For Information (RFI) related to a potential future 340B rebate model pilot. They discuss the nature of the info requested by HRSA in the RFI, thoughts around including confidential/sensitive information in responses, and general strategies for providing constructive feedback to HRSA regarding an important potential ch...

In this episode, Greg and Rob catch up on various looming deadlines for 340B providers.  That includes submitting responses to the HRSA 340B Rebate Request For Information (RFI), as well as submitting drug purchasing data for the CMS ODACS.   Additionally, they talk about struggles with the 340B/MFP reconciliation process and manufacturer policies requiring claims submission.

As referenced in the episode, here is th...

In this episode, Greg and Rob are joined again by healthcare attorney Emily Cook. They discuss a recent HRSA Information Collection Request (ICR) that describes some changes being made to the 340B enrollment, registration and recertification processes. They also discuss recent industry observations around hospital disproportionate share percentage calculations and impact on 340B Program eligibility.

Going to 340B Coalition Winter C...

In this episode, Rob and Greg are joined by guest Andy Ruskin, healthcare attorney and government payer expert from K&L Gates. They’ll be discussing the 2026 CMS OPPS Final Rule, focusing on the provision related to the ODACS, or Outpatient Drug Acquisition Cost Survey. They’ll review the statutory landscape surrounding the survey, recap past attempts by CMS to lower 340B hospital reimbursement, and discuss consider...

In this episode, Greg and Rob share some initial reactions around the recent judicial activity affecting HRSA's 340B rebate model. They'll discuss thoughts on the federal court ruling that halted the rebate model from going into effect, and also debate what the fallout could be for manufacturers and covered entities given the lack of a regulated deduplication process for MFP and 340B prices. They'll also discuss some of the prelimi...

In this episode, Greg and Rob recap key developments in the 340B space from 2025.  They’ll discuss the flurry of activity in recent months related to 340B rebates, project the impact of the OBBB on DSH hospitals, share insights from HRSA audit trends over the last year, and offer commentary on one of the few high points for 340B providers this year – state legislative activity. Also, Rob offers a heartfelt pep talk...

In this episode, Greg and Rob are joined by Katheryne Richardson of the Beacon team, to discuss frequently asked questions about the upcoming 340B rebate model.  They’ll cover the differences between Beacon applications, commonly asked questions regarding data submission, and tips for covered entities to consider as the implementation date approaches.

Come see us at Booth #1545 during this year’s ASHP Midyear Clini...

In this episode, Greg and Rob catch up on some clarifications gained around the upcoming 340B rebate model, including purchasing requirements and developments with select chain retail pharmacies updating their policies. Additionally, they discuss the CMS CY2026 OPPS final rule that was just published, including potential implications for 340B hospitals.

CMS Hospital Drug Acquisition Cost Survey Info: https://www.cms.gov/medica...

In this episode, Greg and Rob share initial reactions to the HRSA update on 340B rebate model implementation. They’ll review the communication provided by HRSA on October 30th on their website, as well as discuss some of the manufacturer letters published on October 31st, that formally communicate rebate policies to 340B stakeholders.

HRSA 340B Rebate Website: https://www.hrsa.gov/opa/340b-model-pilot-program

Beacon Man...

In this episode, Greg and Rob chat about what the government shutdown might mean for 340B Program oversight in the short-term. They’ll also discuss a flurry of developments from manufacturers recently. Specifically, they’ll highlight efforts to promote more direct-to-consumer (DTC) pathways for obtaining medications, all related to a recent Trump Administration executive order calling for “most favored nation (MFN...

In this episode, Greg and Rob are joined by SpendMend colleague Heather Lynch, to talk about how H.R.1 (i.e. One Big Beautiful Bill Act, or OBBBA) could impact 340B covered entities in the long run. They’ll discuss how federal Medicaid cuts projected from the bill could influence a trend in lower average DSH% for some hospitals, threatening 340B Program eligibility. They’ll also have a conversation about things hospital...

In this episode, Greg and Rob review recent changes made to the HRSA Audit Data Request List (DRL). They also discuss some of the comments provided by the public to HRSA regarding potential 340B rebate models, debate a recent change to a manufacturer’s contract pharmacy restrictions, and highlight some communication that has gone out to hospitals regarding a proposed CMS 340B drug acquisition cost survey expected in CY26...

In this episode, Greg and Rob catch up on insights gathered and lessons learned from various forums our team has attended over the last few weeks. Also, they discuss the recently posted FAQ page provided by HRSA in response to questions around the 340B Rebate Model Pilot Program.

340B Rebate HRSA FAQ: https://www.hrsa.gov/opa/340b-model-pilot-program

340B Rebate Comments: https://www.regulations.gov/document/HRSA-2025-000...

In this episode, Greg and Rob discuss tips for completing the annual 340B hospital recertification process, which is occurring now through early September. They also recap a recent notice in the Federal Register that signals HRSA’s intent on modifying some elements of OPAIS and the 340B enrollment/registration/recertification process. The guys also can’t help themselves and wrap up with another debate around impending 3...