The 340B program stands at a critical crossroads in 2026. With the recent court-ordered pause of the rebate pilot program and HHS’s decision to “go back to the drawing board,” covered entities have gained valuable breathing room, but fundamental challenges remain unchanged.
The Strategic Opportunity with the Delay
The recent judicial halt to the 340B rebate pilot doesn’t represent a victory, but rather an opportunity for strategic preparation. In the recent “Navigating the New Frontier: The 340B Rebate Legal Landscape and Technology Solutions” webinar, featuring Ted Slafsky from 340B Report and AJ Rivosecchi from Bluesight, the speakers emphasized that this development represents a delay, not a dismissal.
While HHS reconsiders its approach after court challenges by the American Hospital Association and others, the pharmaceutical industry continues to pursue its interests through multiple channels.
The fundamental takeaway? The healthcare organizations that will thrive aren’t those waiting for final regulatory clarity, but those using this pause to build robust data infrastructure and cross-functional governance.
Data Sovereignty: The Ultimate Strategic Asset
If there’s one concept leaders should focus on in 2026, it’s data sovereignty. The ability to take ownership of your organization’s information ecosystem to prepare for whatever regulatory framework emerges will be instrumental in navigating the future.
True data sovereignty means breaking down silos between:
- Compliance teams focused on 340B eligibility requirements
- Financial teams managing reimbursements and purchasing
- Operational teams handling inventory and dispensing
The organizations best positioned for the uncertain 340B future are those implementing integrated platforms that connect procurement, utilization, and compliance in a unified data environment. With a cross-functional approach, purchasing no longer operates as a series of isolated decisions that put supply, cost, and compliance against each other. Instead, they take into consideration operational and financial implications to allow cost, continuity, and compliance to reinforce each other.
Building Cross-Functional Preparedness
The most forward-thinking healthcare organizations are already:
- Auditing current capabilities: Can you track medications from purchase to individual claims? What is your capacity to self-audit transactions? Covered entities using software solutions such as 340BCheck have quickly expanded from spot audits to 100% audits without adding headcount
- Strengthening governance: Establishing cross-functional 340B steering committees with representation from pharmacy, finance, and compliance
- Prioritizing claims-level visibility: Developing infrastructure to link purchases with patient encounters and prescription data, essential whether dealing with upfront discounts or potential rebate models
- Evaluating vendor partnerships: Demanding clear roadmaps for 340B support from technology partners
The Bigger Picture: Beyond the Rebate Pilot
The current focus on the rebate pilot is just one part of a broader 340B evolution. State legislatures nationwide are considering both protective and restrictive legislation affecting 340B programs. Meanwhile, drug manufacturers continue pushing for greater claims data transparency, not just in contract pharmacy settings but potentially for in-house pharmacy operations as well.
The most successful 340B covered entities will be those that use this delay to build integrated data architecture that can adapt to multiple regulatory scenarios.
Whether the ultimate model involves rebates, enhanced upfront discount validation, or something else entirely, the organizations that master their data will be best positioned to protect their 340B benefits and continue serving their communities.
The time to build that foundation is now, while the regulatory storm has temporarily calmed. To learn about the ways Bluesight can support your 340B strategy, accelerate audits, and scale your program, check out 340BCheck today.
