CMS opened its Medicare Part D Claims Data 340B Repository Oct. 1 for voluntary data submissions, ahead of a proposed Jan. 1, 2027, deadline when submissions would become mandatory for 340B covered entities and their third-party administrators.
Here are four things to know:
- The repository allows covered entities to submit data elements from Part D 340B claims under the Medicare Prescription Drug Inflation Rebate Program.
- The launch lands as 340B stakeholders brace for a cluster of changes taking effect the same day the mandate would begin: 15 more Part D drugs move to negotiated Medicare prices, the CY 2027 Part D benefit redesign applies and a 340B rebate pilot is set to go live, shifting some covered entities from the program’s traditional upfront discount model to a post-sale rebate structure.
- The repository also arrives amid an ongoing standoff between drugmakers and hospitals over claims-level data more broadly. Eli Lilly and Johnson & Johnson have required covered entities to submit claims data directly to them, citing concerns about duplicate discounts under the IRA, a practice AHA and hospital groups have challenged as unlawful.
- Eleven states have enacted laws barring manufacturers from conditioning 340B pricing on claims-data submission. A centralized, CMS-run repository could offer covered entities an alternative path for compliance that does not run directly through individual manufacturers.
Becker’s 3rd Annual Fall Chief Pharmacy Officer Summit is the top tier event that the people leading the future of pharmacy convene. This 3-day event is built specifically for Chief Pharmacy Officers and senior pharmacy leaders. The sessions examine the workforce, financial and clinical priorities shaping pharmacy today. Becker’s is where candid discussions flourish and new ideas thrive. Becker's 3rd Annual Fall Chief Pharmacy Officer Summit
