TAPP Encourages Congress to Support 340B Rebate Model

The Trade Alliance to Promote Prosperity today wrote to members of the Senate Health, Education, Labor, & Pensions (HELP) Committee, House Ways & Means Committee, and House Energy & Commerce Committee to encourage their support of the 340B rebate model under consideration by the Health Resources and Services Administration.

TAPP wrote the following:

[We] are writing to ask for your support of the 340B rebate model under consideration by the Health Resources and Services Administration.

The Trade Alliance to Promote Prosperity recently submitted to the Federal Register comments supporting the agency's proposed 340B rebate model pilot program. You can read our full comments here.

 Executive Summary of TAPP Comments

The proposed rebate model:

  • Is consistent with Section 340B of the Public Health Service Act (PHSA) (42 U.S.C. § 256b).

  • Is necessary to prevent unlawful duplicate discounts in light of the Medicare Drug Price Negotiation Program established under the Inflation Reduction Act (IRA) (42 U.S.C. § 1320f et seq.).

  • Imposes negligible financing costs on covered entities based on independent analysis.

  • Enhances program integrity and transparency.

  • Protects taxpayers from potentially billions of dollars in duplicate discounts.

A claims-level rebate reconciliation mechanism is not only permissible under federal statute—it is increasingly necessary to harmonize overlapping federal drug pricing obligations.

By preventing unlawful duplicate discounts and ensuring that manufacturers provide only the single discount required under law, the 340B rebate pilot protects funding for high-risk biomedical research and U.S. drug innovation, thereby maintaining U.S. leadership globally.

By reducing billions in cost-shifting to the commercial market, it also helps stabilize premiums, limit upward pressure on list prices, and create a more predictable, accountable system that protects consumers and American global competitiveness.

In addition, we encourage you to join the Dear Colleague sign-on letter that Representatives Diana Harshbarger and Buddy Carter have initiated.

Ainsley Shea