Third Circuit Rules Drug Manufacturer 340B Contract Pharmacy Restrictions Are Legal
The U.S. Court of Appeals for the Third Circuit unanimously ruled that manufacturer restrictions on 340B contract pharmacy access are lawful and HRSA’s policy prohibiting them is unlawful. 18 manufacturers now restrict contract pharmacy access.
Devastating for FQHCs without in-house pharmacies who rely on contract pharmacy arrangements for 340B savings. Combined with the rebate pilot court-ordered pause and expanded audit requirements, 340B contract pharmacy revenue faces pressure from three directions.
Primary source
Bass Berry & SimsSource packet
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FQHC Talent. (2026, January 30). Third Circuit Rules Drug Manufacturer 340B Contract Pharmacy Restrictions Are Legal. Primary source: Bass Berry & Sims. Retrieved July 28, 2026, from https://www.fqhctalent.com/intel/third-circuit-340b-contract-pharmacy-restrictions-legal
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