NCODA Position Statement on 340B: The Benefit Must Follow Patients
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: Do patients benefit?
NCODA believes the future of 340B reform must be built on a simple principle: The benefit should follow patients, and the savings should reach patients.
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 patients 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 patients.
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 Patients
340B savings should be connected to patients receiving care—not the ownership structure of the organization billing for services.
It is NCODA’s position that any modernization of the 340B program must be accompanied by a clear, nationally consistent patient definition and appropriate safeguards. The program should ensure that 340B benefits are directed to patients for whom the program was intended, while preventing arrangements that expand eligibility without a meaningful clinical relationship, care coordination responsibility, accountability, and transparency. If the benefit is to follow patients, policymakers must first clearly define who qualifies as a 340B patient and how that benefit is delivered and documented. NCODA supports comprehensive modernization of the 340B program that strengthens accountability and preserves its intended purpose, rather than simply expanding program eligibility.
Consistent with these principles, NCODA’s vision for a patient-centered 340B program is dependent on a clear and consistently applied patient definition that ensures program benefits are directed to the patients for whom the program was intended, while preserving the program’s intended scope.
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. This approach would help ensure the long-term sustainability, while strengthening public trust, confidence, and integrity in the 340B program.
The Path Forward
NCODA supports meaningful reform that is measured not by participation in the program, but by the benefit delivered to patients. NCODA recognizes and supports collaborative efforts, including ASAP 340B, that advance meaningful reforms centered on patient benefit, accountability, and program integrity. 4
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 patients.
The savings should reach patients.
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
- The Alliance to Save America’s 340B Program (ASAP 340B). What We Stand For: Policy Principles. https://www.asap340b.org/what-we-stand-for