340B Drug Rebate Models: Status and Litigation Update

Four drug manufacturers have announced plans to offer discounted drug prices to safety net providers under the federal 340B program via rebates instead of upfront discounts, despite the federal government’s position that manufacturers cannot do so without prior approval. The Health Resources and Services Administration (HRSA) has threatened two manufacturers with enforcement actions if they proceed with implementation, and all four manufacturers and a drug industry vendor have filed lawsuits…
By: Bass, Berry & Sims PLC