340B Reform, PBM Policy Among 2027 Issues to Watch: Adam Colborn, JD

Reform of the 340B Drug Pricing Program is among the most closely watched federal health policy issues heading into 2027, according to Adam Colborn, JD, vice president of government affairs at the Academy of Managed Care Pharmacy (AMCP), in an interview at AMCP Nexus 2026.

Colborn, a panelist in the “Federal Legislative and Regulatory Update” session, said 340B reform is likely “the newsiest” of the issues he is tracking. He also pointed to pharmacy benefit manager (PBM) reform, which Congress enacted in February after years of debate. Other issues on his radar include the Department of Labor’s PBM transparency rule, the Federal Trade Commission’s (FTC’s) settlement agreements with the 3 largest PBMs, and site-neutral payment in Medicare.

Although site-neutral payment may have greater implications for Medicare Part B than Medicare Advantage, the proposal could affect all types of payers, Colborn said. Whether the FTC settlements will result in major change remains to be seen, he added.

Turning to 340B, Colborn noted that lawmakers have introduced numerous bills, including the 340B Access Act, the Sustain 340B Act, and 340B for Patients. Although most proposals define a patient as someone who has had an in-person visit within the past 2 years, they differ in how they address telehealth and use 340B revenue to reduce patient costs.

Contract pharmacies are another key difference among the proposals. The 340B for Patients discussion draft from Senator Bill Cassidy, MD (R-Louisiana), would limit covered entities to 5 contract pharmacies, excluding mail-order pharmacies. Another proposal would codify longstanding guidance allowing covered entities to maintain an unlimited number of contract pharmacy relationships.

The proposals take a more similar approach to transparency, including requirements for 340B claims identifiers and reporting on how 340B revenue is used. Three of the bills would delay or eliminate the Health Resources and Services Administration rebate model scheduled to launch January 1, 2027. In addition, 2 bills would establish a national clearinghouse to prevent duplicate discounts involving Medicaid, Most Favored Nation pricing, or Maximum Fair Prices under the Inflation Reduction Act.

Looking ahead to the 120th Congress, Colborn said the requests for information that Senate Democrats published earlier this year “could be a useful guide for tracking health care in 2027.”