HRSA 340B Rebate Pilot Comment Window Closes April 20 — AHA + NACHC File Opposition; Novartis Entresto Plan Active April 1
HRSA's 340B Rebate Model Pilot RFI comment period closed April 20, 2026 with thousands of comments filed — AHA and NACHC both filed formal opposition citing FQHC cash-flow risk. Separately, Novartis launched its Entresto rebate plan effective April 1, 2026 — the 10th drug-manufacturer rebate program implemented before the 4th Circuit's WV SB 325 ruling blocked further restrictions.
Cash-flow impact: rebate model shifts FQHCs from upfront drug discount to retroactive reimbursement, requiring 30-90 days of working capital reserve to bridge. CA FQHCs heavily dependent on 340B revenue (AltaMed, FHCSD, San Ysidro, Vista, Asian Health Services) face material liquidity risk if rebate model returns post-rulemaking.
HRSA must now reconcile comments before re-issuing.
Key takeaways
- April 20 comment window closed — thousands filed
- Novartis Entresto rebate active April 1 (10th drug)
- 30-90 day working capital reserve needed if rebate returns
- AltaMed, FHCSD, San Ysidro most exposed in CA
Primary source
American Hospital AssociationSource packet
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Affected FQHCs
FQHC Talent. (2026, April 20). HRSA 340B Rebate Pilot Comment Window Closes April 20 — AHA + NACHC File Opposition; Novartis Entresto Plan Active April 1. Primary source: American Hospital Association. Retrieved July 30, 2026, from https://www.fqhctalent.com/intel/aha-340b-rebate-rfi-april-20-close-novartis-april-1
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