340B Drug Pricing Program
ADAP Advocacy’s 340B Project is centered around patient-centric reforms, deeply rooted in the 1983 Denver Principles’ ethic "Nothing About Us Without Us." The project is anchored by a 35-member patient advisory committee comprised of patients not only living with HIV/AIDS, but also other chronic health conditions and rare—including ankylosing spondylitis, cancer, cystic fibrosis, diabetes, lupus, and Myasthenia Gravis (MG).
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According to the Health Resources and Services Administration (HRSA), revenues generated by the 340B Drug Pricing Program are intended to be leveraged by healthcare organizations, or what are referred to as covered entities, for the purpose of increasing access to care and treatment for vulnerable patient populations living with conditions that require costly outpatient medications and treatments (United States, Government Accountability Office, 2023). Concerns about the use of those dollars have long existed, particularly regarding reporting requirements and disparate levels of transparency and accountability across covered entities. ADAP Advocacy supports a robust 340B Program, but one that is designed to help patients, rather than a profiteering enterprise for covered entities.
The 340B Project’s work encompasses data collection, policy analysis, videos, and personal stories to shape the organization’s policy priorities surrounding the 340B Program. The centerpiece of this project’s advocacy work is its 340Bmap.org. Hospital revenues and CEO compensation have risen significantly, while hospital charity care has decreased. The map below shows this trend across hospitals, nonprofit health centers, and HIV care sites that serve as covered entities. This map illustrates why patients keep asking, “Is the 340B Program the next ‘Too Big To Fail?’”
Click here to share your thoughts about 340B covered entity transparency on our Discussion Board.
The Opacity Behind the 340B-Eligible Hospital Transparency
(July 9, 2026)
What happens when one of the only ways a 340B Drug Pricing Program-eligible Covered Entity (CE) can be evaluated relies on a single line item on a federal tax form? This is one of the primary questions that 340B reform advocates must grapple with, and a point that 340B-eligible hospitals consistently rail against (American Hospital Association, 2025). The debate over what hospitals hide from consumers of healthcare services, patients, is a growing storm inside the Washington Beltway and across the nation.
Blogs
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BACK TO TOP340B Drug Pricing Program: Too Big To Fail? Charity Care
(December 2025)
Congress created the 340B Drug Pricing Program to extend federal resources and improve patient care. The Affordable Care Act added requirements for hospitals to provide free care and financial aid to poor patients, also known as charity care.
INFOGRAPHICS
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BACK TO TOPHow the 340B Program Lost Its Way
(February 11, 2026)
The 340B Drug Pricing Program was built on a simple idea: hospitals that serve low-income and uninsured patients could buy drugs at a discount and use the savings to help those who can’t afford care.
Op Eds
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BACK TO TOP340B PROGRAM: The Glue That Should Hold Our Healthcare System Together
(June 2026)
The 340B Drug Pricing Program should literally be the glue holding the American healthcare system together. It certainly has the potential to do so, and in some (unfortunately, too few) cases, it does so.
Policy Papers
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BACK TO TOPRE: Agency Information Collection Activities: Proposed Collection: Public Comment Request; Information Collection Request Title: 340B Rebate Model Pilot Program Application, Implementation, and Evaluation, OMB Number 0906-NEW
(July 8, 2026)
Thank you for the opportunity to comment on the preliminary Paperwork Reduction Act (PRA) determinations that the U.S. Department of Health and Human Services has adopted in connection with its forthcoming adoption of a rebate model to limit duplicate discounts under the 340B Drug Pricing Program in connection with Medicare Fair Price (MFP) drugs. In its Notice, the Department states the correct standard, which is what the incremental effort, if any, will be for rebate data obligations–above the separate efforts already undertaken by covered entities to collect, maintain, transmit, audit, and otherwise manage 340B claims data. Although the Department applies the correct standard, we believe it does not apply it correctly. Based on our analyses, virtually every component of the Department’s analysis overstates—substantially—the effort required of covered entities.
Public Comments
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BACK TO TOP340B Map
ADAP Advocacy's interactive 340B Map shows trends across hospitals, nonprofit health centers, and HIV care sites that serve as covered entities. This map illustrates why patients keep asking, “Is the 340B Program the next ‘Too Big To Fail?”
Tools
Executive Compensation & Charity Care (Data Sets)
Full Data Analysis - 340B Program Eligibility, Executive Compensation, and Charity Care - Cumulative - (October 2023 - February 2025)
Data Analysis - 340B Program Eligibility, Executive Compensation, and Charity Care - Initial 69 CEs - (October 2023 | July 2024)
Data Analysis - 340B Program Eligibility, Executive Compensation, and Charity Care - Added 33 CEs - (February 2025)
Data Analysis - 340B Program Eligibility, Executive Compensation, and Charity Care - Added 68 CEs - (May 2025 - November 2025)
Fact Sheets