340B Rebate Model Pilot Program Update: Operational Readiness, Key Data Elements & What to Prepare Now

In this episode, Katy breaks down what covered entities need to know to prepare for a rebate-based 340B model, including the data elements, workflows, and operational controls that may be required. Important update: after this episode was recorded, a federal court issued a preliminary injunction (Dec. 29, 2025) temporarily blocking HRSA’s 340B Rebate Model Pilot Program from going live on Jan. 1, 2026. While implementation is paused, the readiness concepts discussed remain highly relevant for strengthening data integrity, oversight, and preparedness for future changes.