“Reliance on contract pharmacy is incredibly risky right now.” Nicole Shoquist, JPS Health Network
Meanwhile, several states have enacted laws to protect covered entities from these restrictions, but most are tied up in court. Emily Cook noted that some early rulings have favored states, hinting at possible momentum at the state level even if federal reform stalls
Transparency is coming, and it could be a good thing
Key insight: Prepare now for increased reporting and public accountability.
Panelists agreed that more explicit reporting on 340B savings use is inevitable—potentially even as part of future federal legislation. While many hospitals fear an increased administrative burden or misinterpretation of data, experts say this is also an opportunity.
“There are great stories to tell. We just need to find better ways to tell them.” Ted Slafsky
Emily Cook recommended visible, public-facing examples like signage on mobile clinics or school-based programs to illustrate the impact of 340B. Transparency should not only be reactive but proactive, helping stakeholders and communities understand the value of the program.
Misconceptions about ‘profits’ undermine the mission
Key insight: 340B critics often misunderstand the nonprofit reality.
Panelists pushed back hard on the narrative that hospitals are profiteering from 340B. Only nonprofit and government hospitals can participate in the 340B program, and 340B savings often fund essential, margin-negative services that would otherwise be unavailable.
“Critics should walk the halls of safety-net hospitals before making assumptions.” Nicole Shoquist
From mobile health vans serving the unhoused to school-based clinics providing asthma care, these programs depend on 340B. Leaders should frame the conversation around community impact and access to care, not margins.
How to prepare your organization
The direction is clear even if the timing is not. The programs that do well will be the ones that can show their work. Four areas are worth attention now.
Governance and accountability
Set up an internal structure responsible for 340B oversight, data integrity, and reporting to leadership and the board. Keep it broader than pharmacy. Analytics, compliance, patient access, and community engagement all have a stake in how the program runs and how it gets described.
Data architecture
Your reporting will only be as good as the data underneath it. Invest in tools that can ingest electronic medical record (EMR), third-party administrator (TPA), dispensing, and contract pharmacy data, support standardized 340B data models, and handle the mismatches that come with running multiple EMRs and multiple TPAs.
Metrics and a transparency plan
Define key performance indicators (KPIs) you can report internally and, when the time comes, publish. At minimum:
- Capture rate, meaning eligible prescriptions measured against prescriptions actually captured
- Margin per 340B-eligible fill
- Number of 340B patients reached, with attention to underserved and low-income patients
- Readmission improvement attributable to 340B revenue and integrated program management
- Pharmacy margins
- Contract pharmacy network growth
- Community services funded with 340B revenue
Some health systems are going further and publishing 340B impact reports that connect savings to outcomes: patients served, clinics opened, readmission rates improved. That connection supports the case that 340B is about community health rather than revenue alone.
Risk management
Greater transparency brings greater scrutiny. Audits and public attention both become more likely as program data becomes easier to compare across health systems. Strengthen your documentation, audit trails, standardized contract pharmacy processes, manufacturer restriction tracking, and eligibility records before anyone asks to see them.
Further reading
- Navigating 340B challenges webinar
- Use AI to optimize your health system’s 340B program
- How does 340B impact specialty pharmacy?
- How to align 340B with value-based care: A framework for success
- 4 Tips to Protect Your 340B Program Benefits
Learn more
Want to increase your pharmacy’s value and improve patient outcomes? Learn about our 340B optimization services.
“There’s going to be a tremendous amount of attention… but whether any of it gets to the finish line is unclear.” Ted Slafsky, 340B Report
Contract pharmacy: The legal and strategic battleground
Key insight: Covered entities should not rely on contract pharmacy strategies alone.
Over 40 manufacturers have restricted contract pharmacy use for hospitals, with ongoing litigation dragging out solutions. Nicole Shoquist advised that internal capture strategies, such as bringing prescriptions back into entity-owned pharmacies, are more reliable in the near term.
“Reliance on contract pharmacy is incredibly risky right now.” Nicole Shoquist, JPS Health Network
Meanwhile, several states have enacted laws to protect covered entities from these restrictions, but most are tied up in court. Emily Cook noted that some early rulings have favored states, hinting at possible momentum at the state level even if federal reform stalls
Transparency is coming, and it could be a good thing
Key insight: Prepare now for increased reporting and public accountability.
Panelists agreed that more explicit reporting on 340B savings use is inevitable—potentially even as part of future federal legislation. While many hospitals fear an increased administrative burden or misinterpretation of data, experts say this is also an opportunity.
“There are great stories to tell. We just need to find better ways to tell them.” Ted Slafsky
Emily Cook recommended visible, public-facing examples like signage on mobile clinics or school-based programs to illustrate the impact of 340B. Transparency should not only be reactive but proactive, helping stakeholders and communities understand the value of the program.
Misconceptions about ‘profits’ undermine the mission
Key insight: 340B critics often misunderstand the nonprofit reality.
Panelists pushed back hard on the narrative that hospitals are profiteering from 340B. Only nonprofit and government hospitals can participate in the 340B program, and 340B savings often fund essential, margin-negative services that would otherwise be unavailable.
“Critics should walk the halls of safety-net hospitals before making assumptions.” Nicole Shoquist
From mobile health vans serving the unhoused to school-based clinics providing asthma care, these programs depend on 340B. Leaders should frame the conversation around community impact and access to care, not margins.
How to prepare your organization
The direction is clear even if the timing is not. The programs that do well will be the ones that can show their work. Four areas are worth attention now.
Governance and accountability
Set up an internal structure responsible for 340B oversight, data integrity, and reporting to leadership and the board. Keep it broader than pharmacy. Analytics, compliance, patient access, and community engagement all have a stake in how the program runs and how it gets described.
Data architecture
Your reporting will only be as good as the data underneath it. Invest in tools that can ingest electronic medical record (EMR), third-party administrator (TPA), dispensing, and contract pharmacy data, support standardized 340B data models, and handle the mismatches that come with running multiple EMRs and multiple TPAs.
Metrics and a transparency plan
Define key performance indicators (KPIs) you can report internally and, when the time comes, publish. At minimum:
- Capture rate, meaning eligible prescriptions measured against prescriptions actually captured
- Margin per 340B-eligible fill
- Number of 340B patients reached, with attention to underserved and low-income patients
- Readmission improvement attributable to 340B revenue and integrated program management
- Pharmacy margins
- Contract pharmacy network growth
- Community services funded with 340B revenue
Some health systems are going further and publishing 340B impact reports that connect savings to outcomes: patients served, clinics opened, readmission rates improved. That connection supports the case that 340B is about community health rather than revenue alone.
Risk management
Greater transparency brings greater scrutiny. Audits and public attention both become more likely as program data becomes easier to compare across health systems. Strengthen your documentation, audit trails, standardized contract pharmacy processes, manufacturer restriction tracking, and eligibility records before anyone asks to see them.
Further reading
- Navigating 340B challenges webinar
- Use AI to optimize your health system’s 340B program
- How does 340B impact specialty pharmacy?
- How to align 340B with value-based care: A framework for success
- 4 Tips to Protect Your 340B Program Benefits
Learn more
Want to increase your pharmacy’s value and improve patient outcomes? Learn about our 340B optimization services.
As the 340B program faces unprecedented pressure from legislators, manufacturers, and courts, health system leaders must prepare for a new era of increased scrutiny, legal complexity, and strategic adaptation.
That was the clear message from a recent expert-led webinar hosted by Maxor, where thought leaders Ted Slafsky (340B Report), Emily Cook (McDermott Will & Emery), and Nicole Shoquist (JPS Health Network) offered real-time insights into the evolving 340B landscape. Moderated by Maxor’s VP of commercial analytics, William Riley, the session zeroed in on legislative and legal threats, contract pharmacy restrictions, transparency debates, and what hospitals must do to protect and future-proof their programs.
Here are the top takeaways for health system leaders:
- Legislative change is likely, but the direction is uncertain
- Contract pharmacy: The legal and strategic battleground
- Transparency is coming, and it could be a good thing
- Misconceptions about ‘profits’ undermine the mission
Legislative change is likely, but the direction is uncertain
Key insight: Expect movement on Capitol Hill—but not necessarily in favor of hospitals.
With new leadership in key congressional committees, including known 340B skeptics, pressure on the program is ramping up. While some champions like Senate Majority Leader John Thune may seek bipartisan solutions to restore contract pharmacy access, the current political climate makes a sweeping federal fix uncertain.
“There’s going to be a tremendous amount of attention… but whether any of it gets to the finish line is unclear.” Ted Slafsky, 340B Report
Contract pharmacy: The legal and strategic battleground
Key insight: Covered entities should not rely on contract pharmacy strategies alone.
Over 40 manufacturers have restricted contract pharmacy use for hospitals, with ongoing litigation dragging out solutions. Nicole Shoquist advised that internal capture strategies, such as bringing prescriptions back into entity-owned pharmacies, are more reliable in the near term.
“Reliance on contract pharmacy is incredibly risky right now.” Nicole Shoquist, JPS Health Network
Meanwhile, several states have enacted laws to protect covered entities from these restrictions, but most are tied up in court. Emily Cook noted that some early rulings have favored states, hinting at possible momentum at the state level even if federal reform stalls
Transparency is coming, and it could be a good thing
Key insight: Prepare now for increased reporting and public accountability.
Panelists agreed that more explicit reporting on 340B savings use is inevitable—potentially even as part of future federal legislation. While many hospitals fear an increased administrative burden or misinterpretation of data, experts say this is also an opportunity.
“There are great stories to tell. We just need to find better ways to tell them.” Ted Slafsky
Emily Cook recommended visible, public-facing examples like signage on mobile clinics or school-based programs to illustrate the impact of 340B. Transparency should not only be reactive but proactive, helping stakeholders and communities understand the value of the program.
Misconceptions about ‘profits’ undermine the mission
Key insight: 340B critics often misunderstand the nonprofit reality.
Panelists pushed back hard on the narrative that hospitals are profiteering from 340B. Only nonprofit and government hospitals can participate in the 340B program, and 340B savings often fund essential, margin-negative services that would otherwise be unavailable.
“Critics should walk the halls of safety-net hospitals before making assumptions.” Nicole Shoquist
From mobile health vans serving the unhoused to school-based clinics providing asthma care, these programs depend on 340B. Leaders should frame the conversation around community impact and access to care, not margins.
How to prepare your organization
The direction is clear even if the timing is not. The programs that do well will be the ones that can show their work. Four areas are worth attention now.
Governance and accountability
Set up an internal structure responsible for 340B oversight, data integrity, and reporting to leadership and the board. Keep it broader than pharmacy. Analytics, compliance, patient access, and community engagement all have a stake in how the program runs and how it gets described.
Data architecture
Your reporting will only be as good as the data underneath it. Invest in tools that can ingest electronic medical record (EMR), third-party administrator (TPA), dispensing, and contract pharmacy data, support standardized 340B data models, and handle the mismatches that come with running multiple EMRs and multiple TPAs.
Metrics and a transparency plan
Define key performance indicators (KPIs) you can report internally and, when the time comes, publish. At minimum:
- Capture rate, meaning eligible prescriptions measured against prescriptions actually captured
- Margin per 340B-eligible fill
- Number of 340B patients reached, with attention to underserved and low-income patients
- Readmission improvement attributable to 340B revenue and integrated program management
- Pharmacy margins
- Contract pharmacy network growth
- Community services funded with 340B revenue
Some health systems are going further and publishing 340B impact reports that connect savings to outcomes: patients served, clinics opened, readmission rates improved. That connection supports the case that 340B is about community health rather than revenue alone.
Risk management
Greater transparency brings greater scrutiny. Audits and public attention both become more likely as program data becomes easier to compare across health systems. Strengthen your documentation, audit trails, standardized contract pharmacy processes, manufacturer restriction tracking, and eligibility records before anyone asks to see them.
Further reading
- Navigating 340B challenges webinar
- Use AI to optimize your health system’s 340B program
- How does 340B impact specialty pharmacy?
- How to align 340B with value-based care: A framework for success
- 4 Tips to Protect Your 340B Program Benefits
Learn more
Want to increase your pharmacy’s value and improve patient outcomes? Learn about our 340B optimization services.