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New York 340B Update – Reporting Requirements & Contract Pharmacy Protections

October 2, 2025

New York state is moving to the forefront of 340B legislation in 2025 and 2026. Lawmakers are considering multiple bills that could significantly impact covered entities, from new reporting obligations to protections for contract pharmacy access. For covered entities, community health centers, and hospitals, these proposals could shape how 340B programs are operated and sustained in the state.

Here are some noteworthy Bills & Outlooks:

1. The 340B Provider Reporting Bill (A.6987)

Introduced by Assembly member Amanda Septimo on March 18, 2025, this legislation would require all covered entities in New York to file annual public reports detailing how they use and generate 340B savings.

Key reporting requirements beginning April 1, 2026 include:

  • Financial Transparency:
    • Total acquisition costs vs. reimbursements received for all 340B drugs, broken down by payer type (Medicaid, Medicare, commercial, uninsured).
    • Total number of 340B prescriptions dispensed and percentage of overall prescriptions.
  • Support for Low-Income Patients:
    • Percentage of patients accessing 340B prescriptions through a sliding fee scale.
    • Costs allocated to direct pass-through savings and charity care.
  • Payments to Partners:
    • Total amounts paid to contract pharmacies (with in-state vs. out-of-state breakdown).
    • Payments to third-party administrators (TPAs), legal, compliance, or educational vendors.
  • Contract Pharmacy Oversight:
    • Number of in-state and out-of-state contract pharmacies.
    • Prescription volume by location.
    • Remuneration retained by pharmacies and percentage change year-over-year.

All reports would be certified by a senior officer and posted on a publicly accessible state website, introducing a new level of accountability and scrutiny.

Impact on covered entities:
This bill would require major data tracking and reporting infrastructure. Entities may need to work closely with TPAs and finance teams to ensure data accuracy. Public posting of reports could also influence how patients, legislators, and advocacy groups view the value of 340B savings.

2. Contract Pharmacy Protection Bills (S.1913 / A.6222)

While transparency is a focus of A.6987, lawmakers are simultaneously moving to protect contract pharmacy access.

  • Senate Bill S.1913 was introduced January 14, 2025, by Sen. Gustavo Rivera and co-sponsors. It cleared the Senate Health Committee with a 14–1 vote and is now in the Finance Committee.
  • Assembly Bill A.6222, introduced February 27, 2025, by Assemblymember Amy Paulin and 13 co-sponsors, remains under review in the Assembly Health Committee.

What these bills would do:
The legislation, known as the 340B Prescription Drug Anti-Discrimination Act, prohibits manufacturers, PBMs, and other intermediaries from:

  • Denying or conditioning access to drugs based on 340B participation.
  • Imposing discriminatory reimbursement terms, audits, or fees on covered entities and contract pharmacies.
  • Limiting dispensing or distribution to 340B providers.

Violations could result in civil monetary penalties, with enforcement authority given to the Commissioner of Health, the Department of Education, and the Attorney General’s office.

Impact on covered entities:
If passed, these bills would provide covered entities and patients with stronger legal protections against manufacturer restrictions—helping ensure that 340B drugs remain accessible through local and contract pharmacies.

3. What Covered Entities Should Do Now

  • Prepare for Reporting: Begin evaluating whether your systems can track the specific financial and patient-level data required under A.6987. Consider working with your TPA to assess readiness.
  • Monitor Advocacy Efforts: Contract pharmacy protections remain a critical issue nationwide. Covered entities should follow New York’s progress closely.
  • Evaluate Communication Plans: If reports become public, entities may need to prepare messaging for patients, community stakeholders, and policymakers to demonstrate how 340B savings are reinvested into patient care.

New York’s proposals highlight a growing national trend: greater transparency paired with stronger protections. For covered entities, this means balancing compliance obligations with advocacy to ensure patients continue to benefit from 340B savings.

At RxTrail, we’ll continue to track these developments and provide updates to help covered entities stay prepared and compliant. If you’d like to schedule a discovery call to explore how these upcoming events might impact your 340B program, our team is here to help.

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