Deborah Dempsey, Pharm.D., MBA, RPh, on 340B discounts vs. rebates | PBMI 2026

When a prescription is filled at a pharmacy covered by the 340B Drug Pricing Program, the health plan footing the bill can lose out the drugmaker rebate on that prescription, according to Deborah Dempsey, Pharm.D., MBA, RPh, chief operating officer of ProAct, a mid-size pharmacy benefit manager headquartered in Syracuse, New York.

Dempsey spoke with Managed Healthcare Executive about 340B discounts and manufacturers’ rebates last week at the 2026 Pharmacy Benefit Management Institute (PBMI) Annual National Conference in Orlando, Florida.

Manufacturers do not apply 340B discounts and rebates to the same claim, explained Dempsey. Stacking both would likely push the combined discount past the cost of the drug itself. When a claim adjudicates through a 340B-associated pharmacy and provider, it is paid at a 340B discounted price.

That leaves the plan sponsor paying full price for the medication, she explained, while the financial benefit of the lower acquisition cost goes to the 340B-covered entity. Sponsors accustomed to receiving a rebate on a given claim can lose that revenue.

Dempsey said the issue of what has been called 340B erosion from the plan sponsor point of view has existed for years but is now drawing scrutiny as plan sponsors better understand how pharmacy benefits and rebates work and start asking harder questions about their own claims.

Dempsey spoke with MHE after participating in a panel at the PBMI conference titled “340B and the Employer: Rebate Erosion, Transparency and What Comes Next.” She was joined on the panel by Mary Bellanti, RPh, vice president of clinical strategy and sales at MedImpact; Karen van Caulil, Ph.D., president and CEO of the Florida Alliance for Healthcare Value; and Jeff Dunn, Pharm.D., MBA, president and CEO of NeosRx.