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Ohio has enacted a new state-level 340B reporting requirement, and covered entities participating in the program are now required to submit detailed program data to the Ohio Department of Health each year. This article outlines what the law requires, what the ODH collection tool asks for, and where covered entities can expect to find the necessary data.
Ohio's 340B reporting requirement was enacted as part of the state's 2026-2027 budget bill (House Bill 96), signed into law on June 30, 2025, with the reporting provisions becoming effective September 30, 2025. It requires covered entities participating in the 340B Drug Pricing Program to submit detailed program data to the Ohio Department of Health (ODH) each year, with the first submission due July 1, 2026. ODH is required to post the submitted data publicly.
This is not a federal HRSA requirement. It sits alongside existing 340B compliance obligations as a separate, state-level transparency measure. Ohio joins a small but growing group of states that have enacted their own 340B reporting laws.
It is also worth knowing that the original bill language was more prescriptive than what became law. Governor DeWine's veto message removed several detailed provisions, including specific charity care and low-income patient definitions and granular contract-pharmacy comparisons, while keeping the core reporting requirement intact. The result is a requirement ODH has more flexibility to administer, which is reflected in the collection tool it eventually released.
ODH has published its reporting template, and it covers more ground than a simple summary. For each covered entity, it asks for data across three separate categories: drugs dispensed through in-house pharmacies, drugs dispensed through contract pharmacies, and administered drugs. Within each category, covered entities report acquisition costs, payments received, and prescription counts, broken out by payer type: Commercial/Private Insurance, Medicare, Medicaid, Other Third-Party Payor, and Uninsured/Self-Pay. Collection tool
Beyond the payer-type breakdowns, the form also asks for:
Entity identification — HRSA 340B ID and every National Provider Identifier associated with the covered entity, not including contract pharmacies.
Administrative costs — payments to contract pharmacies, third-party administrators, consulting entities, and software or IT vendors, plus internal staffing and IT costs for running the 340B program.
Contract pharmacy count — the total number of contract pharmacies associated with the covered entity.
Use of 340B savings — an itemized list of programs, services, and equipment funded with 340B profits, with a narrative option if a detailed breakdown is not feasible.
The most common obstacle covered entities run into is not knowing what to report. It is knowing which system already has it. In practice, most of the required data is spread across three places: a 340B software platform or third-party administrator, which typically holds acquisition costs, payments, and prescription counts by payer type; a pharmacy or EHR system, which holds administered drug data and NPI records; and the finance or accounting team, which holds vendor payments, internal costs, and the starting point for the itemized 340B spend breakdown.
Pulling from three sources and reconciling them into one submission takes real coordination. That is the part of this requirement that tends to take longer than expected.
Confirm your status with ODH. If your organization has not yet submitted, a direct call to ODH is the fastest way to confirm where things stand.
Start the data pull. Even without a live deadline pressure point, the sooner the data collection starts, the more accurate the final submission will be.
Assign a single owner. A report that touches three different systems needs one person coordinating it, or it tends to stall between departments.
Treat this as a template for next year. Ohio's reporting requirement is annual. Building a repeatable process now, rather than a one-time scramble, makes each future year easier.
One detail worth knowing: the statute itself does not include a stated penalty for late submission. That does not make the requirement optional, but it does mean a late, accurate report is a better outcome than a rushed, incomplete one.
We work with covered entities on state-level 340B changes like this one. Our role is to map a covered entity's existing systems, TPA, EHR, and finance records, to each line on the ODH form, so the data gathering happens once and correctly rather than through repeated back-and-forth.
Is this the same as HRSA's 340B reporting requirements?
No. This is a separate, state-level requirement specific to Ohio, in addition to existing federal 340B compliance obligations.
What happens if we miss the deadline?
The statute does not specify a penalty for late submission. Submitting complete and accurate data late is preferable to submitting incomplete data on time.
Do contract pharmacies need to be listed as NPIs?
No. The covered entity's own NPIs are reported separately from its contract pharmacies.
Is this data made public?
Yes. ODH is required to post submitted reports on its website.
Will this requirement change next year?
It is possible. Since this is the first reporting cycle, ODH may adjust its collection process or template based on what it learns this year.
What period does the first report cover?
The first submission covers the reporting period of January 1, 2025 through December 31, 2025, based on ODH's collection tool.
