The 340B Rebate Model is Paused: What This Means for Covered Entities

While Verity and Covered Entities were preparing for the Department of Health and Human Services (HHS) to launch their 340B Rebate Model on January 1, 2026, the model is currently paused due to a legal challenge to the program. On December 29, 2025, days before the pilot was set to launch, a Maine federal district judge issued a preliminary injunction pausing the pilot. HHS subsequently appealed to reinstate the program, which was denied by the 1^st Circuit Court on January 7, 2026. In a significant development, the federal government announced on January 12, 2026, that it intends to withdraw its appeal  of the injunction blocking the 340B Rebate Model Pilot. In a statement addressed to the 1^st Circuit Court of Appeals, the U.S. Department of Health and Human Services (HHS) and the American Hospital Association (AHA) indicate they “plan to dismiss the appeal in short order.”

This means that HHS will no longer be appealing the decision and the injunction will stand, preventing the 340B Rebate Model from going forward until and unless the Court decides otherwise. This decision marks a notable reversal for HHS from defending the rebate pilot after ongoing court rulings.

With the appeal dropped, implementation of the rebate model is halted for the foreseeable future, and Covered Entities (CEs) will continue operating under the existing 340B program rules for all drugs.

Looking Ahead

Verity is actively monitoring developments and will keep you informed where 340B management processes may be impacted. While the Rebate Model Pilot is paused indefinitely, our focus remains on helping the 340B community navigate important transitions with confidence.

We know rules and regulations can shift quickly—so when change comes, our teams and technologies adapt. No matter how the 340B program may evolve in the future, Verity will be prepared to support you with timely updates, practical guidance, and agile solutions.

Stay informed: bookmark the Verity blog to keep the latest guidance and actionable steps within reach. Interested in becoming a Verity customer? Let’s talk.