As Congress considers reforms to the 340B Drug Pricing Program, Advocates for Community Health (ACH) has taken an active role in shaping policy proposals that reflect the operational realities of community health centers and prioritize patient access. Through sustained engagement with lawmakers around its innovative 340C legislative framework, ACH has helped advance reform concepts that are now reflected in current legislative proposals, including H.R. 7391, sponsored by Rep. Jack Bergman (R-MI) and Auchincloss (D-MA) that exempts health centers from the rebate model, introduced in the House on February 5, 2026.
ACH’s work is guided by a clear objective: ensuring that the 340B program remains a reliable tool for community health centers to stretch limited resources, expand access to care, and reinvest savings directly into patient services while increasing transparency and accountability for all stakeholders.
Guiding Principles for 340B Reform
ACH’s positions on 340B are grounded in a consistent set of principles informed by health center experience shared directly by our members. ACH believes that effective reform should:
- Preserve patient access to affordable medications
- Maintain flexibility for community health centers to stretch scarce federal resources
- Strengthen program integrity without imposing unnecessary administrative burden
- Ensure that 340B savings continue to be reinvested directly into patient care
These principles have shaped ACH’s evaluation of existing legislation and its broader engagement with policymakers.
ACH’s Positions on Current 340B Legislation
ACH supports targeted legislative efforts that reinforce access and program stability, including H.R. 7635 – the 340B PATIENTS Act, which clarifies manufacturers’ obligations to provide 340B pricing regardless of how medications are dispensed. ACH has consistently emphasized that contract pharmacy arrangements are essential to ensuring patients can access medications in their communities.
As noted above, ACH also has endorsed H.R. 7391, the Community Health Center Drug Pricing Protection Act, to ensure community health centers are not subject to a rebate model in the 340B program.
At the same time, ACH has expressed significant concerns with, H.R. 8574 – the 340B ACCESS Act, a broader reform proposal, in its current form. ACH has noted that several provisions would reduce the value of the 340B program for community health centers and introduce operational constraints that could limit patient access. ACH has communicated these concerns directly to policymakers while offering alternative approaches informed by health center experience.
Committed to engaging all possible paths for meaningful reform that improves the 340B Program while also protecting health centers, ACH has been optimistic about and engaged with the Senate’s Bipartisan Gang of Six Working Group and the work it is doing to build consensus around reform for the 340B program. In April 2024, ACH submitted comments on the Senate Working Group’s SUSTAIN 340B discussion draft. Half of the working group members have changed since the discussion draft was released, and the new group is undergoing regular discussions on next steps. ACH is in regular contact with all six current members.
ACH’s Opposition to the 340B Rebate Model
ACH has been outspoken in opposing proposals to shift the 340B program from its current upfront discount structure to a rebate-based model. Drawing on direct input from community health centers, ACH has emphasized that a rebate model would introduce delays, uncertainty, and administrative complexity that community health center providers are not positioned to absorb.
ACH has raised concerns that a rebate model would:
- Shift financial risk onto health centers by requiring payment at full price upfront
- Create cash-flow challenges that could limit patient access to medications
- Increase administrative burden and compliance complexity
- Undermine the predictability health centers rely on to plan services and staffing
ACH has communicated these concerns to Congress and federal agencies, including spearheading a stakeholder letter signed by over 260 organizations, underscoring that a rebate model would weaken, rather than strengthen, the 340B program.
From 340C to a Framework for Reform
Recognizing the need for a more constructive approach to reform, ACH developed 340C in 2022 as a health center–informed framework aimed at balancing access, accountability, and sustainability. The framework sought to move the 340B policy conversation beyond defending the status quo and toward reforms that strengthen the program while preserving its core purpose.
Key elements of the 340C framework are echoed in relevant legislative proposals, including the draft SUSTAIN legislation from the Senate’s “Gang of Six,” which was not introduced but was circulated to select stakeholders. These elements include:
- Recognition of the essential role of contract pharmacies in patient access
- Clearer expectations around program participation and oversight
- Transparency approaches that protect patient care and health center operations
- A rejection of rebate-based approaches in favor of predictable, upfront discounts
The framework and accompanying guidance were developed with ACH’s community health center member input, helping ensure these concepts reflect real-world program use.
Constructive and Ongoing Role in 340B Reform
ACH’s engagement on 340B reflects a commitment to advancing practical, patient-centered reforms. By articulating clear principles, taking positions on existing legislation, opposing proposals that would destabilize the safety net, and advancing a detailed framework through 340C, ACH has contributed meaningfully to the direction of current reform efforts.
As Congress continues its work on 340B, ACH remains committed to working with lawmakers and stakeholders to ensure the program continues to support community health centers and the patients they serve.