340B Rebate Model Pilot FAQ: What to Do Before January 1, 2027

No, not if you registered last year. But you do need to confirm your documents. Beacon requires your organization to do this directly, so NuvemRx can't complete it for you. You don't need a new W-9 unless your W-9 information has changed.

Action · By Dec 15: Log in to Beacon and confirm your ASO, business verification, and organization detail documents.

Yes. Five manufacturers require a new bank letter: Amgen, Astellas, BMS, AbbVie, and Pfizer. Without one, their rebate payments may be delayed.

Three others have their own requirements. GSK says a new bank letter may be required. Merck requires one for new users. Teva requires ACH micro-deposit verification.

Action · By Dec 15: Upload new bank letters in Beacon for Amgen, Astellas, BMS, AbbVie, and Pfizer.

Beacon needs these documents for each covered entity you register:

• EIN (IRS Employer Identification Number)
• IRS CP 575 letter showing the entity's address
• Articles of Incorporation
• W-9
• Bank letter from a US financial institution, for ACH payments

Beacon takes up to 5 business days to review a registration before you can finish setting up your account. If you're adding an entity to an existing account, use Beacon's "Register an Additional Entity" process.

Action · As early as possible: Gather these documents and submit your registration well before January 1, so the 5-day review doesn't run into the holidays.

Yes. Beacon pays rebates by ACH, and it verifies bank details separately for each 340B ID. Verification uses your bank letter and a small test deposit (a "penny test"). If your account has several 340B IDs, any ID without verified banking can't receive rebate payments.

Action · By Dec 15: Confirm that banking is set up and verified for every 340B ID on your Beacon account.

Yes, once you select NuvemRx as your TPA in Beacon's 340B Rebate platform. If NuvemRx is your TPA, your claims will be automatically submitted to Beacon for approval, and we will provide approval and rebate information to you.

If NuvemRx is your TPA and manages your pharmacies, we will also manage denied claims as they are received.

If NuvemRx is your TPA only, your Client Success Manager (CSM) will guide you on how to correct and resubmit recoverable denials. You still receive rebate payments. We do the rest.

Action · By Dec 15: Select NuvemRx as your TPA in Beacon. Your NuvemRx CSM will walk you through the steps.

Yes. Several manufacturers have said they'll deny rebate claims from pharmacies that "don't comply with the rebate model," citing their program integrity requirements. A pharmacy that isn't registered and active in 340B ESP is the most likely trigger for a denial.

Action · By Dec 15: Review every pharmacy in your network, confirm each one is registered and active in 340B ESP, and follow up with any that aren't. Aim for 100% before December 15.

Yes, for up to two packages per drug (NDC) dispensed between December 17 and December 31.

Clear them. NuvemRx will clear accumulations for all claims we manage for you. If remaining accumulations are replenished at the 340B price after January 1 and the same claims are also rebated, you risk a duplicate discount finding at audit.

Action · Dec 17–31: If NuvemRx is your TPA: we'll clear your accumulators. Your NuvemRx CSM will guide you through this process.

If another TPA serves some of your locations, work with that TPA to clear them, or stop ordering in-scope drugs on your 340B account from Dec 17–31 and resume on Jan 1 at WAC.

To be eligible for a 340B rebate, in-scope drugs must be purchased on your 340B account. If NuvemRx is your TPA, we handle this for you. Purchases on any other account aren't eligible for rebate.

Action · From Jan 1: Buy in-scope drugs on your 340B account only.

No. Only dispensed drugs are eligible.

Action · Ongoing: Keep returning unused inventory through your normal return channels. 

If it comes up, you'll need proof of the link between each claim and the cash you received from its rebate. That same link supports a Good Faith Inquiry (GFI), if you ever need to file one. Talk to your NuvemRx CSM about how we can support this.

Action · From Jan 1: Be ready to show the claim-to-rebate-payment link for every claim from January 1 forward. This applies to all clients, including Pharmacy Management clients.

The reversal counts against future rebates.

Action · Ongoing: Expect reversal offsets when you reconcile rebate payments.

No. Where both apply, you get the lower of the two. Beacon tracks manufacturer policies, and manufacturer policies specify which rebate will be awarded. Beacon applies these rules by manufacturer. Learn more about manufacturer MFP policies here.

If you have a contract pharmacy network, you may need to recover MFP refund dollars from your pharmacies.

Action · By Dec 15: Get familiar with manufacturer MFP policies, then discuss MFP exclusions with your NuvemRx CSM.

It varies by manufacturer. Each manufacturer's 340B rebate policy explains how it handles MFP and the 340B rebate on the same claim. Beacon posts the latest version of each policy: download manufacturer 340B Rebate Policy documents here.

Action · By Dec 15: Review the 340B rebate policy for each manufacturer whose in-scope drugs you dispense. Policies can change, so check for the latest version.