What the approved plans say, what NuvemRx already has running for its clients, and the six things left on your list before the first rebate claim goes to Beacon.
In August, nothing about the rebate pilot was settled. Now most of it is.
HRSA approved 10 manufacturer plans covering 21 drugs. Those drugs move to a rebate. Every other 340B drug keeps the upfront discount you have today.
From January 1, you run two 340B models at once.
For 21 drugs in the 2027 HRSA Rebate Pilot scope, your 340B discount shifts from an upfront discount to a rebate paid after the dispense. You, the covered entity, purchase the drug at wholesale acquisition cost (WAC), submit claim data to Beacon's 340B Rebate platform within 45 days of dispense, and receive a manufacturer rebate for the difference of WAC minus 340B price within 10 days on claims that pass validation. The rebate is issued through the Beacon platform directly to you.
The 21 include Eliquis, Jardiance, Farxiga, Januvia/Janumet, Linzess, Vraylar, Trelegy/Breo, Austedo, Otezla, Enbrel and others. GLP-1s (Ozempic, Wegovy) are unchanged: Novo Nordisk did not join the pilot.
Mission Control is our team of NuvemRx experts, working with data from 800+ covered entities. When the plans landed, the first question we put to that data was simple: how much of a health center's 340B program do these 21 drugs actually touch? A small share of claims carries a big share of savings. That's real cash flow shifting from the day you buy to the day you're paid.
At an entity-owned pharmacy, 20% of savings rides on 3% of claims. Those are the dollars that move from the day you buy to the day Beacon pays. That's why we treat January 1 as a pharmacy-and-finance event, and why the work below starts now.
The NuvemRx Regulatory Working Group reviewed every approved plan. All 10 run on Beacon with the same 45-day/10-day clock. Where they differ is what happens when a Medicare price was already applied, and what Beacon needs from you to pay, including whether covered entities already registered on Beacon's 340B Rebate platform need a new bank letter.
Where the plans diverge: MFP handling (4 pay-and-adjust, 3 may deny the 340B rebate, GSK reserves the right, 2 silent); bank letters (5 require, GSK may); pharmacy eligibility (Merck explicit; AbbVie, BMS, GSK via Beacon's check against their policies).
Medicare Maximum Fair Price—where both apply you receive the lower of the two, not both. Common to all ten: Beacon platform, 45-day submission window, 10-day pay-or-deny, quarterly NDC-11 price file, two-package carry-over for 12/17–12/31 dispenses. Sources: approved manufacturer plans dated 9/11–10/3/26. Not legal advice.
Starting January 1, 2027, NuvemRx will support the HRSA Rebate Model. For every client:
NuPharmacy clients (NuvemRx as your Entity-owned pharmacy manager). When a rebate request is denied, NuvemRx corrects and resubmits your recoverable denials for you, for the sites we manage. For denials that cannot be resolved, NuvemRx will advise you on how to prevent the same denial going forward.
NuTPA clients (NuvemRx supporting your contract pharmacy networks). When a rebate request is denied, NuvemRx Client Success Managers give you guidance on how to correct and resubmit recoverable denials, from the same playbook our pharmacists use. For denials that are not recoverable, NuvemRx advises you on how to prevent the same denial going forward. As your TPA, NuvemRx also keeps denied claims out of replenishment, loads the quarterly 340B price file, and from Dec 17–31 applies the two-package carry-over, then clears your in-scope accumulators.
NuReferrals clients. NuvemRx expedites rebate-eligible referral claims through NuReferrals workflow so that all eligible claims are submitted within the 45-day submission window. NuvemRx expects minimal impact to referrals, and we are monitoring the workflow closely.
In August, we gave you six things to do before January. Here are six again, updated for approved plans. These require your signature, your bank, or your pharmacy—we cannot do them for you.
1. By December 15, 2026, confirm your registration with Beacon to avoid rebate delays/denials. To receive rebates, your covered entity must be registered on Beacon's 340B Rebate platform. You may want to set up a separate bank account for 340B rebate deposits, so rebate dollars stay traceable apart from MFP refunds. If you do, make sure your bank letter is for that account.
2. Add users and select NuvemRx as your TPA on Beacon. This lets your team review rebates or start good faith inquiries (GFIs), and lets NuvemRx submit claims for you automatically (if we are your TPA).
3. Register all of your pharmacies on 340B ESP. Every pharmacy in your network must also be active on Beacon's 340B ESP platform. Many manufacturers check a pharmacy's ESP status to confirm it's eligible. Rebates for unregistered pharmacies may be delayed or denied. Start here. Target: 100% of pharmacies active in 340B ESP by Dec 15.
4. Place your final 340B reorders for the 21 in-scope drugs by December 15, to take advantage of transitional rebate opportunities.
5. Plan the cash before you need it. Look at extending wholesaler payment terms or your credit line to cover the WAC-to-rebate gap. Plan for a rebate reserve (~40 days of in-scope spend) and a claim-to-cash trail for every rebate. And if you haven't already, set up the separate rebate account from step 1.
6. Get the counter ready. Brief pharmacy staff on the four denial drivers: exact NDC, prescriber NPI, BIN/PCN, date of service. From January 1 forward, submit reconsideration for denied claims in the Beacon portal. And decide on patient pricing now: if your sliding fee scale is tied to acquisition cost, a WAC purchase price mechanically raises what an uninsured patient could be charged. The complexity of a rebate model belongs with us. It shouldn't reach the counter.
Contract pharmacy and in-house data rules kept tightening. These are the dates that need action before the rebate goes live.
Legal challenges to the pilot are possible, but plan for a live January 1—everything above is worth doing either way.
For most community health centers, pharmacy is the engine. It generates the savings that pay for the extended hours, the added provider, the program that never had a grant behind it. A rebate model puts a delay between that engine and the care it funds, and asks you to prove every claim along the way.
The health centers that come through January without a gap in care will be the ones that treated pharmacy as the engine early: registered, reordered, reserved, and backed by a team that already built the workflow. That's what our clients have going into January 1. Submission is automatic. Reconciliation is claim by claim. Denials have an owner.
It also matters who's doing that work for you. A rebate pilot is exactly where an administrator's incentives show. NuvemRx has no PBM or wholesaler parent, so there's no other side of the table. We're 100% dedicated to safety-net providers, with zero confirmed HRSA audit findings in 10+ years across all of NuvemRx.
The rebate changes when the money arrives. Our job is making sure it still arrives in time to pay for the care it was always meant to fund.
Working with a NuvemRx Client Success Manager? Your CSM will work with you on every NuvemRx-related item above. Questions? Contact your CSM.
Not yet a client? Start a conversation below—or take these six and run them yourself.
Bookmark this link for continually updated resources and insights to help pharmacy become the engine that drives expanded care for your community.
This article is general information for 340B covered entities and is not legal, tax, accounting, or financial advice. It reflects HRSA's 340B Rebate Model Pilot Program, approved manufacturer plans dated 9/11–10/3/26, the NuvemRx 2027 Rebate Model Overview, and NuvemRx claims January–June 2026 (shares approximate, by drug cohort), as of October 14, 2026. Consult your own advisors, and read the plans that apply to your organization.