Moving oversight of the 340B Drug Pricing Program from HRSA to CMS has the potential to be the most consequential drug pricing governance decision of the Trump era—but it has barely registered outside of trade press.
The administration has now proposed a shift in back-to-back annual budget requests, framing it as a streamlining move that would place 340B under an agency with existing drug pricing infrastructure. That framing undersells what is actually at stake.
CMS has demonstrated an appetite for reimbursement cuts in this space, most notably cutting Medicare reimbursement rates for drugs dispensed through 340B hospitals by 28.5% in 2018 (before the Supreme Court struck down those cuts in 2022). Putting CMS in charge of a program that hospitals have come to rely on as a financial lifeline should invite some questions.
That reliance is not incidental. Medicare reimbursement has lost roughly 7.7% in purchasing power since 2020, with cumulative IPPS updates trailing inflation by a wide margin, and MedPAC projects the aggregate FFS Medicare margin will still be around negative 10% in 2026. Medicaid faces further pressure from the state-directed payment caps in the One Big Beautiful Bill. Therefore, safety-net hospitals are utilizing 340B revenues to offset what government payers aren’t covering—and considerably more in some cases, as a recent PhRMA campaign has argued.
Such context makes the CMS question urgent. HRSA has governed 340B with a relatively light hand; its new rebate pilot, launched earlier this year, is its most assertive reform move to date. CMS would likely bring tighter audit authority—but whether the agency has the incentive to reform the program is a bigger question.
340B’s growth is fundamentally cost-shifting, not cost-saving, with the “discount” absorbed by drug manufacturers, commercial insurers, employers and other purchasers. Meanwhile hospitals keep the spread between the discounted price and what they’re reimbursed.
It would stand to reason that CMS would have little financial reason to disturb an arrangement that bolsters hospital bottom lines without touching the federal budget. Program purchases have grown from an estimated $7.5 billion in 2013 to a record $100 billion in 2025. This growth has continued in part because no single agency has had both the authority and the incentive to rein it in. CMS may finally supply the authority. Whether it also supplies the incentive remains to be seen.
– Leslie Isenegger, Head of Policy, Public Affairs and Access, RC Resolve