Federal Court Overturns HRSA 340B Child Site Registration Requirement — Expands Satellite Location Purchasing
A federal district court vacated HRSA's requirement that off-site facilities (child sites) must appear on a hospital's Medicare cost report and be registered in OPAIS before purchasing drugs at 340B prices. This effectively restores flexibilities that existed during the pandemic era, potentially expanding 340B purchasing eligibility for FQHCs with satellite locations or off-site services.
The ruling is part of a broader wave of judicial pushback against HRSA 340B program administration in early 2026.
Key takeaways
- HRSA child site registration requirement vacated — satellite locations may now purchase at 340B prices without prior OPAIS registration
- Restores pandemic-era flexibilities for off-site 340B purchasing
- FQHCs with satellite clinics or mobile units should review whether this expands their 340B eligibility
Primary source
Forvis MazarsSource packet
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FQHC Talent. (2026, March 3). Federal Court Overturns HRSA 340B Child Site Registration Requirement — Expands Satellite Location Purchasing. Primary source: Forvis Mazars. Retrieved July 28, 2026, from https://www.fqhctalent.com/intel/340b-child-site-registration-requirement-overturned
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