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?”
Blogs
Are 340B Covered Entities Sacrificing Affordable Care for Executive Compensation?
(February 5, 2026)
The 340B Drug Pricing Program was founded on a straightforward accountability agreement: in return for significant discounts on outpatient medications, safety-net providers would “stretch scarce federal resources” to make healthcare more accessible and affordable for those most in need.
View our blogs archive.
BACK TO TOPWhy the 340B ACCESS Act Prioritizes Patients
(November 20, 2025)
In September 2025, Representatives Earl L. “Buddy” Carter (R-GA) and Diana Harshberger (R-TN) introduced the 340B Affording Care for Communities and Ensuring a Strong Safety-Net (ACCESS) Act. H.R.5256 attempts to rein in what members of both parties have come to view as the excesses of the 340B Drug Pricing Program.
INFOGRAPHICS
340B 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.
340B Drug Pricing Program: Too Big To Fail? Executive Compensation - Part 1
(November 2025)
The 340B Drug Pricing Program was designed to help poor patients access healthcare services. Yet, despite this program growing to $66 billion, manufacturer rebates are being used to fund excessive compensation for hospital CEOs.
340B Drug Pricing Program: Too Big To Fail? Executive Compensation - Part 2
(November 2025)
The 340B Drug Pricing Program was designed to help poor patients access healthcare services. Yet, despite this program growing to $66 billion, manufacturer rebates are being used to fund excessive compensation for hospital CEOs.
340B Drug Pricing Program: Too Big To Fail? Medical Debt - Part 2
(September 2025)
Sadly, many hospitals participating in the 340B Drug Pricing Program are threatening patients with aggressive, predatory debt collection…often damaging consumer credit reports.
View our infographics archive.
BACK TO TOPOp Eds
How 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.
View our opinion pieces archive.
BACK TO TOPToo Big to Care: How PBMs Are Undermining HIV Care
(November 14, 2025)
We have spent our lives fighting for people living with HIV because we are among them. We have sat in waiting rooms doing the math on whether to pay for prescriptions or the train fare home, and we have watched community clinics struggle to stretch every dollar.
Policy Papers
REBATE VS. REVENUE: The Accountability Crisis Threatening the 340B Program
(March 2026)
Covered entities, pharmaceutical manufacturers, trade associations, and lobbyists at both the federal and state levels must recall the foundational goal of the federal 340B Drug Pricing Program: to address specific healthcare needs while achieving substantial outcomes. The path forward is not about expansion but about strategic evaluation.
View our policy papers archive.
BACK TO TOPThe 340B Drug Pricing Program and its Potential Impacts on Annual Revenues, Executive Compensation, and Charity Care Provision in Eligible Covered Entities – Supplemental Report 2
(December 2025)
According to the Health Resources and Services Administration (HRSA), revenues generated by the 340B Drug Pricing Program are intended to be leveraged to increase access to care and treatment for vulnerable patient populations living with conditions that require costly outpatient medications and treatments.
Public Comments
RE: 340B Rebate Model Pilot [HHS Docket No. HRSA–2025–14619]
(September 8, 2025)
ADAP Advocacy is writing to you to urge you to modify the Health Resources and Services Administration (HRSA) proposed rebate pilot. The HRSA proposal, as it currently stands, is deeply flawed and invites challenge under the Administrative Procedure Act.
RE: Proposed 340B Rebate Model Pilot Program (HHS Docket No. HRSA-2026-03042)
(April 19, 2026)
On behalf of the ADAP Advocacy Association, thank you for the opportunity to submit comments regarding this critically important Request for Information on the proposed rebate model under the 340B Drug Pricing Program.
View our public comments archive.
BACK TO TOPTools
340B 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?”
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