The Survey That Could Reset Your 340B Economics
CMS finalized the Drug Acquisition Cost Survey requirement in the CY 2026 OPPS final rule. The CY 2026 OPPS final rule established a Drug Acquisition Cost Survey requiring 340B hospitals to report actual acquisition costs for specified outpatient drugs. The initial survey period ran from January through March 2026, covering drug purchases from July 2024 through June 2025.
This isn’t optional. Failure to submit complete and accurate data can result in payment adjustments and potential compliance referrals.
The survey targets the gap between what 340B hospitals pay for drugs and what Medicare reimburses. CMS has signaled for years that it considers the current ASP-based reimbursement methodology to be overpaying 340B hospitals. This survey is the data collection mechanism that could support future payment reforms.
What the Survey Requires
The survey applies to 340B-covered entity hospitals paid under OPPS. It covers separately payable drugs, which are drugs currently reimbursed at ASP+6% under the hospital outpatient payment system.
Hospitals must report the actual 340B ceiling price or sub-ceiling price paid for each NDC, the volume of each drug purchased at 340B pricing during the reporting quarter, and the corresponding Medicare utilization for those drugs.
CMS will use this data to calculate the spread between acquisition cost and reimbursement. The agency has not yet specified how it will use the results, but the OPPS final rule language makes clear that payment policy changes are the intended outcome.
Operational Readiness Checklist
July is closer than most pharmacy departments think. Here’s what needs to happen now.
Audit your drug purchasing data. Ensure your 340B split billing system accurately captures which drugs were purchased at 340B prices versus WAC or GPO pricing. Errors in purchase classification will corrupt your survey responses.
Reconcile your NDC-level inventory records. The survey requires NDC-specific reporting. If your pharmacy system tracks drugs at the therapeutic class level but not the NDC level, you need to close that gap before the first submission.
Establish a reporting workflow. Identify who owns the data extraction, who reviews it for accuracy, and who submits the survey. Build in a quality check step. CMS will be validating submissions against its own utilization data.
Document your methodology. If CMS questions a submission, you need to demonstrate how you calculated acquisition costs. Keep records of your data sources, extraction methods, and any manual adjustments.
The Bigger Picture: What Comes After the Survey
CMS has been methodical about this. The agency tried to cut 340B drug reimbursement from ASP+6% to ASP-22.5% in 2018. The Supreme Court struck that down in 2022 in American Hospital Association v. Becerra, ruling that CMS hadn’t conducted the required survey before adjusting rates.
Now CMS is conducting the survey. The legal obstacle that protected 340B hospitals has been removed.
Hospitals should model what their Medicare outpatient drug reimbursement would look like under various payment reduction scenarios. If CMS moves to an acquisition-cost-based reimbursement model, the 340B savings margin on Medicare Part B drugs could shrink significantly.
This doesn’t mean 340B goes away. But it means hospitals that depend on 340B Medicare margin to fund uncompensated care need contingency plans. The time to build those plans is before the data starts flowing to CMS.
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