Throughout my career—from working in the Senate to leading policy reform campaigns for patients nationwide, I've seen the same problem play out repeatedly. As healthcare affordability remains one of the single biggest challenges facing everyday Americans, patients aren’t worried about the complicated backend mechanisms intended to make their prescriptions affordable. They care about one simple thing: whether they can afford the medicine they need at the pharmacy counter.
One of those mechanisms, the 340B Drug Pricing program, was designed to help low-income and underserved patients access discounted medicines. But for far too many, that isn’t the case. What began as a safety-net initiative has grown into a massive, multi-billion-dollar system—scaling past $100 billion in annual purchases—yet it operates with startlingly little transparency.
Patients shouldn’t need a degree in healthcare economics to track how discount dollars move between hospitals, pharmacies, insurers, and middlemen. However, because the program lacks basic visibility, we often can’t verify whether these steep discounts are actually lowering out of pocket costs for the vulnerable patients Congress created 340B to serve.
Luckily, the environment for administrative accountability is shifting. The Health Resources and Services Administration (HRSA) recently announced a revised 340B Rebate Model Pilot Program. This updated pilot—which builds on key lessons and legal challenges from earlier attempts—marks a crucial step toward restoring accountability to a federal program that has grown disconnected from the patients it was created to serve.
Under the traditional model, discounts are provided to covered entities, making it difficult to verify where the money ends up. HRSA’s revised pilot introduces a clear, claims-based rebate system for select high-cost drugs. By converting discounts into verifiable post-dispensing rebates, the model makes it far easier to validate legitimate claims, prevent duplicate discounting, and track savings through the system.
We know this mechanism works because it’s already proven effective in other federal healthcare programs like Medicaid. Applying a similar approach to 340B is a common-sense step to modernize a program that expanded far beyond its original scope without the proper guardrails.
Congress has increasingly taken notice of 340B, holding hearings that examine its rapid growth, lack of transparency, and impact on health care costs. Lawmakers have put forward various proposals detailing regulatory mechanisms, including the 340B ACCESS Act, the 340B SUSTAIN Act, and Senator Bill Cassidy's recent draft legislation. All are aimed at ensuring 340B savings translate directly into patient relief.
I've spent enough time in public policy reform and advocacy to know that drug pricing isn’t an abstract policy debate--it is a daily crisis for families across this country. Our polling data at Patients Come First highlights just how eager the public is for action. A recent survey revealed that 77 percent of Americans believe hospitals and healthcare providers should be legally required to pass drug discount savings directly to patients to lower out-of-pocket costs. An overwhelming majority also wants Congress to close policy loopholes and enforce strict transparency so these discounts fulfill their original mission.
HRSA’s revised rebate pilot is an encouraging step toward making life-saving treatments affordable. But an administrative step is only as meaningful as the legislative follow-through. Congress must build on HRSA’s momentum by passing reforms that mandate full transparency, eliminate middleman markups, and guarantee that 340B savings land where they belong: in the pockets of everyday patients.
Kasia Mulligan is the National Spokesperson for Patients Come First.
