340B Unscripted

Ep 82 | Recap of 340B Developments from 2025

In this episode, Greg and Rob recap key developments in the 340B space from 2025.  They’ll discuss the flurry of activity in recent months related to 340B rebates, project the impact of the OBBB on DSH hospitals, share insights from HRSA audit trends over the last year, and offer commentary on one of the few high points for 340B providers this year – state legislative activity. Also, Rob offers a heartfelt pep talk for 340B folks at the end of the episode – so make sure you listen through to the end!
Medi-Cal Provider Guidance on 340B Rebates:  https://mcweb.apps.prd.cammis.medi-cal.ca.gov/news/33779
Email us at 340BUnscripted@spendmend.com with your questions and comments!

Ep 81 | 340B Rebate Q&A with Beacon

In this episode, Greg and Rob are joined by Katheryne Richardson of the Beacon team, to discuss frequently asked questions about the upcoming 340B rebate model.  They’ll cover the differences between Beacon applications, commonly asked questions regarding data submission, and tips for covered entities to consider as the implementation date approaches.
Come see us at Booth #1545 during this year’s ASHP Midyear Clinical Meeting!

Ep 80 | 340B Updates, including CMS CY26 OPPS Final Rule and Rebate Developments

In this episode, Greg and Rob catch up on some clarifications gained around the upcoming 340B rebate model, including purchasing requirements and developments with select chain retail pharmacies updating their policies. Additionally, they discuss the CMS CY2026 OPPS final rule that was just published, including potential implications for 340B hospitals.
CMS Hospital Drug Acquisition Cost Survey Info: https://www.cms.gov/medicare/payment/prospective-payment-systems/hospital-outpatient-pps/outpatient-prospective-payment-system-opps-drug-acquisition-cost-survey
Come see us at booth #1545 at the ASHP Clinical Midyear Meeting December 8-11 in Las Vegas!

Ep 79 | 340B Rebate Model Update

In this episode, Greg and Rob share initial reactions to the HRSA update on 340B rebate model implementation. They’ll review the communication provided by HRSA on October 30th on their website, as well as discuss some of the manufacturer letters published on October 31st, that formally communicate rebate policies to 340B stakeholders.
 
HRSA 340B Rebate Website: https://www.hrsa.gov/opa/340b-model-pilot-program
Beacon Manufacturer Resources Website (includes letters): https://cm.beaconchannelmanagement.com/pages/resources
 
Email us at 340BUnscripted@spendmend.com with questions, comments and topic suggestions!

Ep 78 | Government Shutdown, Most Favored Nations Pricing and Direct-to-Consumer Pharmacy Supply Chain Discussion

In this episode, Greg and Rob chat about what the government shutdown might mean for 340B Program oversight in the short-term. They’ll also discuss a flurry of developments from manufacturers recently. Specifically, they’ll highlight efforts to promote more direct-to-consumer (DTC) pathways for obtaining medications, all related to a recent Trump Administration executive order calling for “most favored nation (MFN)” pricing for drugs in the U.S.
SpendMend will be at the 340B Grantee Conference in Atlanta October 20 – 22.  Stop by our booth and also catch our presentation at the “Ask the Experts – Open Forum” while you are there!

Ep 77 | DSH Hospital Threats

In this episode, Greg and Rob are joined by SpendMend colleague Heather Lynch, to talk about how H.R.1 (i.e. One Big Beautiful Bill Act, or OBBBA) could impact 340B covered entities in the long run. They’ll discuss how federal Medicaid cuts projected from the bill could influence a trend in lower average DSH% for some hospitals, threatening 340B Program eligibility. They’ll also have a conversation about things hospitals should consider, both in the short term and long term, to brace for the impact.
In the intro, they’ll also catch up on various manufacturer actions affecting 340B providers.
Email us at 340BUnscripted@spendmend.com with questions and comments!

Ep 76 | HRSA DRL Updates & 340B Rebate Comments

In this episode, Greg and Rob review recent changes made to the HRSA Audit Data Request List (DRL). They also discuss some of the comments provided by the public to HRSA regarding potential 340B rebate models, debate a recent change to a manufacturer’s contract pharmacy restrictions, and highlight some communication that has gone out to hospitals regarding a proposed CMS 340B drug acquisition cost survey expected in CY26.
SpendMend’s comments on HRSA’s proposed 340B rebate model: https://www.regulations.gov/comment/HRSA-2025-0001-1115
CMS proposed Medicare Part B 340B drug acquisition cost survey template: CMS-10931 | CMS
 
Got questions? Email us at 340BUnscripted@spendmend.com 

Ep 75 | 340B Rebate Guidance Update – HRSA FAQs

In this episode, Greg and Rob catch up on insights gathered and lessons learned from various forums our team has attended over the last few weeks. Also, they discuss the recently posted FAQ page provided by HRSA in response to questions around the 340B Rebate Model Pilot Program.
340B Rebate HRSA FAQ: https://www.hrsa.gov/opa/340b-model-pilot-program
340B Rebate Comments: https://www.regulations.gov/document/HRSA-2025-0001-0001