NCODA Position Statement on 340B: The Benefit Must Follow the Patient
Published Date:
NCODA supports the original mission of the 340B Drug Pricing Program: helping vulnerable patients gain access to life-saving medications and care.
For years, NCODA has advocated for greater transparency, accountability, and reforms that strengthen the 340B program while preserving its original intent. As policymakers and stakeholders continue to debate the future of the program, the discussion should remain focused on a fundamental question: Does the patient benefit?
NCODA believes the future of 340B reform must be built on a simple principle: The benefit should follow the patient, and the savings should reach the patient.
Today, the value generated by the 340B program is too often determined by ownership structures, acquisition strategies, contract pharmacy arrangements, and site-of-care dynamics rather than the needs of the patient receiving treatment.
The current structure places greater emphasis on organizational participation than on demonstrating direct patient benefit. It creates incentives that do not consistently align with care coordination, patient access, or treatment outcomes. Most importantly, it lacks a consistent requirement to demonstrate that savings generated in a patient’s name directly improve that patient’s access to care.
NCODA believes policymakers should stop asking who should receive the 340B benefit and start asking: where is the benefit going?
The answer should be clear: It should go to the patient.
NCODA Calls for a Patient-Centered Redesign of 340B
As the healthcare landscape continues to evolve, NCODA believes a modernized 340B program should be redesigned around the patient journey and the clinical team responsible for delivering care. NCODA supports reforms that:
Ensure the Benefit Follows the Patient
340B savings should be connected to the patient receiving care—not the ownership structure of the organization billing for services.
In oncology, patients should benefit from the program regardless of whether they receive care in a hospital-owned practice, an independent community oncology practice, or another qualified setting that delivers coordinated, high-quality medically-integrated care1.
Require Demonstrable Patient Benefit
Participation in 340B should require measurable evidence that savings improve patient care through:2
- Reduced out-of-pocket costs
- Faster access to therapy
- Improved medication adherence
- Expanded patient support services
- Enhanced clinical outcomes
- Reduced barriers to treatment
Success should be measured by patient outcomes, not organizational margins.
Support Medically Integrated Oncology Care
Cancer care requires more than access to medications. Successful treatment depends on coordination among oncologists, pharmacists, nurses, financial advocates, navigation teams, and caregivers. Patients achieve the best outcomes when care is delivered through a medically integrated oncology model that connects clinical decision-making, medication management, patient education, financial assistance, adherence support, and care coordination.
340B policy should recognize and support medically integrated oncology care models that improve adherence, reduce treatment delays, manage toxicity, and help patients successfully remain on therapy. The benefit generated through 340B should strengthen the multidisciplinary teams and clinical infrastructure that directly support patients throughout their cancer journey.
Establish True Accountability
Every organization participating in 340B should be able to demonstrate how program savings directly improve access, affordability, and outcomes for patients3. Transparency must be accompanied by accountability. The program should require clear evidence that savings are being reinvested in patient care.
The Path Forward
NCODA supports meaningful reform that is measured not by participation in the program, but by the benefit delivered to the patient. The future of 340B should not be defined by ownership models, dispensing arrangements, or institutional financial interests. It should be defined by patients.
As policymakers consider the future of the program, NCODA urges leaders across healthcare to unite around a principle that transcends politics, organizational interests, and market dynamics:
The benefit should follow the patient.
The savings should reach the patient.
The success of 340B should be measured by patient outcomes, not organizational margins. That is the reform patients deserve. That is the reform NCODA calls upon policymakers to deliver.
References
- National Community Oncology Dispensing Association. Medically Integrated Pharmacy. NCODA. https://ncoda.org/medically-integrated-pharmacy/
- Medicare Payment Advisory Commission (MedPAC). Report to the Congress: Overview of the 340B Drug Pricing Program. Washington, DC: MedPAC. Available at: https://www.medpac.gov/wp-content/uploads/import_data/scrape_files/docs/default-source/reports/may-2015-report-to-the-congress-overview-of-the-340b-drug-pricing-program.pdf
- U.S. Senate Committee on Health, Education, Labor & Pensions, Majority Staff. The 340B Drug Pricing Program: Background, Oversight, and Policy Considerations. U.S. Senate HELP Committee. January 2024. Available at: https://www.help.senate.gov/imo/media/doc/final_340b_majority_staff_reportpdf1.pdf