We were so honored to hear from all the covered entities who attended this year’s 340B Coalition Summer Conference about their experiences, industry challenges, and personal triumphs.   

Published: July 2026

Although the conference has come to a close, let’s not lose the momentum. Now more than ever, staying on top of 340B program changes, requirements, and everyday operations is a must.  

Here’s a list of the CPS team’s top takeaways: 

1. Understand the current 340B state of affairs, define your organization’s ideal future state, and develop a roadmap to bridge the two 
   
   Our very own Dennis Killian, PharmD, PhD, 340B ACE, VP of 340B Solutions, participated in a “Lessons from the Field” presentation where he spoke about policy impacts on 340B compliance and financial stability. Although many variables are outside of covered entities’ control, they can still develop strategies to mitigate risk and create opportunity, such as adding or expanding an in-house retail/specialty pharmacy.  
   
   Several other speakers also discussed the importance of developing and executing a solid outpatient pharmacy strategy. Why? From Dr. Killian’s perspective, it will help covered entities drive long-term sustainability. 
   

2. Prepare for both the expected and the unknown, so you can control the controllable
   

   
   A lot of discussions with covered entities centered around the uncertainty of recent and upcoming policy changes:
   
   Maximum Fair Price (MFP)
   ➜  The Centers for Medicare & Medicaid Services (CMS) will begin accepting voluntary submissions of MFP claims from healthcare organizations on October 1, 2026.
   ➜  Given how time consuming reconciliation is for covered entities to prevent duplicate 340B/MFP discounts, CMS may make that MFP claims submission mandatory.
   ➜  More drugs are added to the MFP list every year, adding to the complexity of managing your 340B programs.
   
   Manufacturer Requirements 
   ➜  Each month, more manufacturers announce new or updated 340B-related policies as others also start to take effect.
   ➜  The time between those announcements and effective dates is quite short—even nonexistent in one case; covered entities have been in “hyperdrive” to adjust operations within that window. 
   ➜  Collectively, these changes may require covered entities to use multiple portals for claim submissions or even collect and submit new data altogether.
   
   340B Rebate Model
   ➜  Although CMS indefinitely delayed the pilot program’s launch, it may come back into play January 1, 2027, which is less than six months away. 
   ➜  Covered entities are concerned they may not have enough time to fully understand the new scope, quantify potential impacts, and effectively prepare for such a change. 
   
   Although some changes may never come to fruition, preparing for them as if they will is important. By putting in the work now, you can take control of what you can when the time comes.  
   
   

   REMINDER
   Covered entities have experienced a lot of pressure before, but health system leaders are resourceful. Even with that pressure, they were able to figure out compliant solutions, and it all worked out.  

    

3. Don't panic—talk to industry experts for peace of mind  
   
   During our conversations with leaders from across the country, several themes emerged: hesitancy, doubt, and fear of the unknown. However, we also found a common denominator. Working with an industry partner who has tenure in the 340B and larger hospital pharmacy space can relieve many of those concerns. 
   
   If you’re looking for additional expertise to support you and your team, check out our solutions and get in touch with us today.
   

    

 
Thank you again to everyone who attended and shared their valuable insight!