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