Health centers should be aware of two significant 340B program changes taking effect on January 1, 2026, both of which will affect pharmacy operations, cash flow, and 340B savings.
- Medicare Maximum Fair Price (MFP) Program:
Medicare will begin using negotiated Maximum Fair Prices for the first 10 high-cost, high-volume Part D drugs. These prices will substantially lower Medicare reimbursement for these medications. Because 340B savings are driven by the difference between reimbursement and the 340B price, health centers should expect a reduction in 340B savings for these drugs starting in 2026.
Pharmacies are also required to register with the Medicare Transaction Facilitator (MTF) to participate in the new pricing and rebate processes.
- HRSA’s 340B Rebate Pilot
For the same set of drugs, HRSA will launch a mandatory 340B rebate model on January 1. Instead of purchasing these drugs at the 340B price, health centers will be required to:
- Purchase the drugs at full Wholesale Acquisition Cost
- Dispense the medication
- Submit claims to receive a rebate
This creates a significant cash-flow burden and a new administrative process, and many contract pharmacies may reconsider whether they carry these medications due to the operational requirements.
Both changes apply to all patients, not just Medicare beneficiaries, meaning the financial and operational impacts will extend across the entire pharmacy program.
CHCANYS held a recent webinar with Colleen Meiman that walks through both changes and how health centers can prepare.
To request the slides and recording, please contact dtobia@chcanys.org.