Are you a contract pharmacy that is coming to terms with the implications of the 340B rebate program and the Medicare Drug Price Negotiation (MDPN) program as they come online on Jan. 1? Here are a couple of key things to remember:
If you process 340B claims for drugs in the MDPN billed to any insurance, it's important to understand how these claims will be handled by both the PBM and the Covered Entity's third-party administrator (TPA). The Covered Entity will no longer be able to purchase MDPN drugs at 340B pricing from the wholesaler. Instead, they will be purchasing 340B MFP drugs at full WAC price from the wholesaler and will need to apply to the Drug Manufacturer for a 340B rebate no matter if the claim is a Medicare claim or not.
For Medicare claims, you'll need clarity on whether you will receive the MDPN rebate from the drug manufacturer, or whether the Covered Entity will instead receive the 340B rebate. Drug Manufacturers will not pay both the MDPN rebate to the pharmacy and a 340B rebate to the drug manufacturer for the same claim.
You should have a reliable method for identifying which Medicare claims involve 340B drugs eligible for MDPN rebates. If you do not receive the MDPN rebate, you must have a process in place to ensure you obtain a replacement product from the Covered Entity for that item.
For non-Medicare MDPN drugs, it is a little easier as there is no MDPN rebate involved. It is advised that you confirm with the Covered Entity and/or TPA how they will handle prescriptions for MFP drugs for both Medicare and non-Medicare claims.
For more information, see here for our recent CE webinar "340B-rrr: Feeling the Chill of the IRA," our FAQ document from the webinar, and a checklist of things that pharmacies need to know for 2026 from Secure340B.
