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HCPF explains billing for HRSA’s 340B rebate‑model pilot: bill post‑rebate ceiling price

November 10, 2025 | Health Care Policy & Financing, Governor's Cabinet, Organizations, Executive, Colorado


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HCPF explains billing for HRSA’s 340B rebate‑model pilot: bill post‑rebate ceiling price
Corey Conallog, the department’s pharmacy policy specialist, briefed attendees on a new Health Resources and Services Administration pilot that changes how certain 340B drug prices are reflected on claims.

Corey said HRSA’s 340B rebate‑model pilot (effective in January) will switch from an upfront 340B discount to a post‑claim rebate issued roughly 10 days after a claim is invoiced. The department’s billing guidance is to bill Medicaid for the submitted ingredient cost after the rebate — equal to the 340B ceiling price — rather than the pre‑rebate price. Providers should be able to view ceiling prices via the Office of Pharmacy Affairs information system, and Corey provided his contact information for follow‑up questions.

Providers with technical questions or who need clarification on operational impacts were advised to reach out to the department contact listed on the slide. No formal billing exceptions or waiver guidance was announced during the meeting.

Next steps: the department will respond to direct inquiries and follow up with stakeholders as needed to clarify billing procedure for the pilot.

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