The 340B Rebate Model Pilot Is Approved. Are You Ready for What’s Next?

On October 30, 2025, the Health Resources and Services Administration (HRSA) approved plans from eight drug manufacturers for the 340B Rebate Model Pilot Program—a significant step for the pilot program intended to launch on January 1, 2026, concurrent with the launch of the first set of Maximum Fair Prices (MFP) for Medicare Part D under the Inflation Reduction Act (IRA). 

Come January 1, the first ten selected drugs included in the Medicare Drug Price Negotiation Program (MDPNP) under the IRA will be purchasable at their negotiated MFP. Because manufacturers are required to offer a lesser discount between 340B pricing and the MFP, the 340B Rebate Model Pilot Program seeks to prevent duplicate discounts by providing rebates instead of upfront 340B discounts for these drugs.  

This 340B Rebate Model Pilot is voluntary for manufacturers, and 340B covered entities must participate in the rebate model pilot to receive 340B discounts. To help covered entities navigate both programs, maximize savings, and deliver patient care without interruption, Verity has spent much of 2025 preparing new solutions and services in advance of January 1, 2026. This article outlines the workflows for claims subject to MFP and the 340B Rebate Model Pilot Program, steps to prepare now, and how Verity’s solutions are optimized to help you succeed.

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Preparing for New Workflows with Verity

Your purchasing workflows will change depending on the type of claim processed: MFP pharmacy claims, or 340B Rebate Pilot pharmacy and medical claims. In this section, we’ll break down the expected flow for each type of claim with new enhancements in the Verity platform, V340B®. 

MFP Claims 

If you have a Medicare Part D patient with an MFP claim: 

1. Patient is prescribed a drug included in the MFP. 

2. The dispensing entity submits the claim to the Medicare D plan or Pharmacy Benefit Manager (PBM). 

3. Verity receives claim information. 

4. V340B will validate the claim and, based on relevant identifiers, begin the claim matching process. 

5. One size does not fit all, so CEs will be able to specify qualifications for NDCs for inclusion or exclusion for V340B to observe. 

6. V340B will run a unique claim-level profitability check to ensure you’re able to benefit from 340B savings. 

7. 340B eligible claims will be designated as ready for submission to Beacon. 

340B Rebate Model Pilot Program Claims 

All approved manufacturers will be using Beacon Channel Management to submit rebate claims. Verity has been actively collaborating with Beacon to develop a fully integrated submission solution for both pharmacy and medical claims—ensuring our clients are ready to participate with confidence. 

If you have a 340B-eligible pharmacy claim: 

1. A 340B-eligible claim is submitted to V340B. 

2. V340B identifies rebate claims by NDC. 

3. Based on the CE’s specified rebate configurations, V340B will review the claim for 340B eligibility. Eligible claims will be flagged for Beacon submission. 

4. At this point, V340B can automatically submit the claim to Beacon on behalf of the CE for rebate claims submitted within 45 days of the dispense date. 
   • Alternatively, CEs can choose to export a Beacon report to manually submit to Beacon. 

If you have a 340B-eligible medical claim: 

1. A 340B-eligible claim is submitted to V340B with the new, additional data required for medical claims. All of these data fields have been added to our Split Transaction data specifications. Current Verity customers can access the updated document via our Help Center, or by reaching out to their Account Manager. 

2. V340B identifies rebate claims by NDC to determine if 340B discounts or MFP is applicable. 

3. Eligible rebate claims will be flagged as ready for submission to Beacon. 

4. At this point, V340B can automatically submit the claim to Beacon on behalf of the CE for rebate claims submitted within 45 days of the dispense date. 
   • Alternatively, CEs can choose to export a Beacon report to manually submit to Beacon. 

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How Verity Is Innovating for Our Customers

As you can see from the above workflows, Verity is releasing several key enhancements ahead of the January 2026 launch to help our clients transition to these new workflows smoothly: 

• The ability to automate submission of 340B rebate claims for pharmacy and medical claims, fully compliant with Beacon requirements. 

• Detailed rebate claims status reporting, enabling you to monitor claim submissions, track the status of your rebates, and confirm rebate payments have been issued. 

• Optimizations for customizing and managing NDC inclusions and exclusions. 

• The inclusion of all new required data fields for submitting medical claims under the 340B Rebate Model Pilot Program. 
  
• Personalized impact assessments for all Verity clients. 

How to Prepare Now 

Don’t wait until December 31^st to define your MFP and 340B Rebate Model Pilot strategy. Here is what you can do right now: 

1. Register with Beacon and designate Verity as your Third-Party Administrator (TPA). 

2. Determine inclusion and exclusion plans for Medicare Part D claims from your 340B program. 

3. Connect with your Verity Account Manager to begin configuring your options in V340B based on your specific program needs. 

4. Visit the Verity Help Center in V340B for additional educational resources, product tutorials, and answers to frequently asked questions. 

Success requires proactive planning, seamless integration, and a clear understanding of evolving compliance requirements. At Verity, we’re committed to guiding you through every step—helping you to optimize your savings, maximize administrative resources, and maintain program integrity. 

Ready to take the next step? Current Verity customers should connect with your Account Manager today to ensure your organization is prepared for January 1 and beyond. For other questions, or to see how Verity can work with you through this transition, contact our dedicated IRA and 340B Rebate Model Pilot support line at Rebates-IRA-Support@verity340b.com.