Episode summary
Holly Herring recorded this episode on 2 October 2026, the day after HRSA approved ten manufacturers for the 2027 rebate pilot.
Covered entities will buy the selected drugs at WAC on their 340B account and claim a rebate after dispense.
WAC prices need to be loaded on the 340B wholesaler account, because purchases on a GPO or WAC account risk denial.
Covered entities have 45 days from dispense to submit a claim for rebate.
Manufacturers have 10 days to pay or deny once they receive a complete submission.
Every correction restarts that 10-day clock, so a late correction can push the claim past the 45-day window.
A claim submitted on day 5 leaves weeks to work through a denial, while a claim submitted on day 40 leaves five days.
Beacon requires penny testing and verification of the account and the covered entity before it can pay.
Entities already registered in Beacon for MFP have to re-verify their bank credentials.
Each manufacturer's operational plan is posted on the HRSA website and needs to be read in full, because details outside the main announcement are easy to miss.
Her first call would be to her 340B team to review TPA configurations, because entities within one health system are often set up differently.
To estimate the cash at stake, pull utilization for the in-scope 11-digit NDCs and apply the gap between WAC and the 340B ceiling price, adjusted for your qualification rate.
Extending wholesaler payment terms can bring the rebate back before the invoice is due.
Entities with heavy oncology populations face the sharpest patient impact, because many in-scope drugs treat cancer.
Holly sees a role for AI in automating good faith inquiry responses inside Beacon.
Pharmacy and finance have to own rebate readiness together, or it will not succeed.
After 90 days, judge the pilot on expected versus realized rebates, denial rates, payment delays and the work it displaced.
Show notes
- Holly Herring recorded this episode on 2 October 2026, the day after HRSA approved ten manufacturers for the 2027 rebate pilot.
- Covered entities will buy the selected drugs at WAC on their 340B account and claim a rebate after dispense.
- WAC prices need to be loaded on the 340B wholesaler account, because purchases on a GPO or WAC account risk denial.
- Covered entities have 45 days from dispense to submit a claim for rebate.
- Manufacturers have 10 days to pay or deny once they receive a complete submission.
- Every correction restarts that 10-day clock, so a late correction can push the claim past the 45-day window.
- A claim submitted on day 5 leaves weeks to work through a denial, while a claim submitted on day 40 leaves five days.
- Beacon requires penny testing and verification of the account and the covered entity before it can pay.
- Entities already registered in Beacon for MFP have to re-verify their bank credentials.
- Each manufacturer's operational plan is posted on the HRSA website and needs to be read in full, because details outside the main announcement are easy to miss.
- Her first call would be to her 340B team to review TPA configurations, because entities within one health system are often set up differently.
- To estimate the cash at stake, pull utilization for the in-scope 11-digit NDCs and apply the gap between WAC and the 340B ceiling price, adjusted for your qualification rate.
- Extending wholesaler payment terms can bring the rebate back before the invoice is due.
- Entities with heavy oncology populations face the sharpest patient impact, because many in-scope drugs treat cancer.
- Holly sees a role for AI in automating good faith inquiry responses inside Beacon.
- Pharmacy and finance have to own rebate readiness together, or it will not succeed.
- After 90 days, judge the pilot on expected versus realized rebates, denial rates, payment delays and the work it displaced.
