By Purnank Gandhi, PharmD, Founder & CEO of GapRx 340B Consultants
Starting January 1, 2027, covered entities will use a post-purchase rebate process for selected drugs from 10 manufacturers through the Beacon platform. That changes a familiar finance task: instead of receiving the 340B discount at purchase, your team will need to track claims from dispense through submission, payment, and ledger reconciliation.
The deadlines make a dependable routine essential. Covered entities must be allowed at least 45 calendar days from the date of dispense to submit required claim data. Once a complete submission is received, the manufacturer must pay or provide a documented denial within 10 calendar days.[^1] A claim that sits unnoticed, or goes back for missing information, can delay cash and complicate your close.
This guide gives your finance and 340B teams a weekly workflow for keeping every pending claim visible.
Know what you’re reconciling
Under the revised pilot, the rebate is calculated at the unit level as WAC minus the 340B ceiling price in effect on the date of dispense. Your tracking system should retain the source values and make the expected rebate traceable to the dispensed product and claim.
HRSA estimates the pilot products represent less than 5.5% of 2025 340B sales volume. That limited overall share does not make the work optional: a claim-level tracking gap can still delay expected revenue or leave your team unable to explain a variance.
For historical context, the earlier pilot intended for 2026 was vacated on February 10, 2026; HRSA announced a revised program on July 31, 2026.[^2] HRSA’s published plans identify 21 product entries across AbbVie, Amgen, Astellas, AstraZeneca, Boehringer Ingelheim, Bristol Myers Squibb, GSK, Merck, Pfizer, and Teva. Confirm each affected NDC-11 and its current routing instructions in the approved drug-list guide.
Build one claims tracker, not another disconnected spreadsheet
Use a centralized tracker or dashboard that finance, pharmacy operations, and your 340B program lead can all access. Assign one accountable owner for keeping each record current.
At a minimum, record:
| Field | Why it matters |
|---|---|
| Date of dispense | Starts the 45-day submission window |
| Manufacturer and drug | Identifies applicable plan and support route |
| NDC-11 | Matches the precise product and package |
| WAC and ceiling price | Supports the expected rebate calculation |
| Submitted date | Shows whether the claim was submitted on time |
| Payment received date | Supports payment aging and cash reconciliation |
| Status | Makes pending, incomplete, denied, and paid claims visible |
Add fields for quantity, calculated expected rebate, dispensing channel and location, claim or transaction ID, submission batch, date the submission was complete, resubmission date, denial reason, follow-up owner, and notes. That complete-submission date is especially important: an incomplete submission does not start the manufacturer’s 10-day payment window. The clock begins once the required information is complete.[^1]
Use consistent status values, such as Ready to submit, Submitted, Incomplete (correction needed, Complete) awaiting payment, Paid, Denied: review, and Escalated. Keep an audit trail of status changes, file confirmations, communications, and corrections.
Set up your weekly cadence
A weekly review is the minimum operating rhythm. Your claims system should still capture submissions, rejections, and payments as they occur; the weekly meeting is where the team clears exceptions and confirms financial exposure.
Monday: Find what is due and what is stuck
- Pull all new and unsubmitted eligible claims, then check required fields, NDC-11 formatting, and manufacturer routing.
- Sort pending claims by days since dispense. Flag claims approaching your internal escalation threshold well before day 45.
- Review incomplete submissions and assign a named owner and correction date to each one.
- Compare the tracker with pharmacy or TPA dispense records to identify missing claims.
Set internal targets that leave room for data correction and platform issues. For example, aim to submit promptly after a claim is validated rather than routinely using the full 45-day period.
Mid-week: Close the exceptions
- Confirm corrections were resubmitted and record the date the submission became complete.
- Review claims awaiting payment against the 10-calendar-day clock, counting from the complete submission, not an earlier incomplete upload.
- Investigate denials or status changes. Save the reason, supporting evidence, and next action.
- Check for duplicate records, reversals, or payer changes that may affect eligibility or routing.
A short mid-week touchpoint can prevent a returned file from sitting unnoticed until the next Monday.
Friday: Reconcile dollars and report exposure
- Match payments to claim IDs and expected rebate amounts. Record payment dates and investigate any difference.
- Update the pending-dollar dashboard and identify claims that are aging, incomplete, denied, or escalated.
- Reconcile submission totals to the source dispense file so you can spot omissions and duplicates.
- Send finance and program leadership a concise summary: opening pending dollars, new claims, payments received, unresolved exceptions, and closing pending dollars.
Keep a rolling dashboard of pending dollars
Finance should be able to answer two questions at a glance: How much rebate is pending, and how old is it? Track expected rebate dollars by manufacturer, drug, channel, submission status, and age band. Useful age bands include not yet submitted, submitted and awaiting payment, incomplete, denied, and escalated.
For each claim, calculate the expected rebate on a consistent unit basis: eligible quantity multiplied by the difference between WAC and the applicable ceiling price. Keep the underlying WAC, ceiling-price source, quantity, and calculation visible. Reconcile actual payments to the claim-level expectation; do not treat a platform status alone as proof that cash was received.
GapRx’s Beacon quick-start guide covers platform readiness and related workflow setup. For broader visibility into claims and program performance, see our 340B analytics and dashboard services.
Watch for four reconciliation pitfalls
1. Claims submitted too close to, or outside, the 45-day window. Late discovery can leave little time to correct missing or rejected data. Monitor claims by dispense date and escalate aging records before they approach the deadline. Do not assume an exception will be granted.
2. Treating an incomplete upload as the start of the payment clock. The manufacturer’s 10-day period follows receipt of a complete submission. Record both the original upload and the complete-submission date so your aging report reflects the correct trigger.
3. Overlooking Medicaid duplicate-discount risk. Reconcile payer and carve status with your Medicaid billing process before submission, and investigate changes, reversals, or crossovers. The rebate workflow does not remove your responsibility to prevent duplicate discounts. See our guide to Medicaid crossovers in the rebate era.
4. Routing split-bill and contract-pharmacy claims incorrectly. Do not rely on a brand name alone or assume every channel follows the same route. Match the NDC-11, dispensing location, channel, manufacturer plan, and applicable platform instructions. Maintain a routing matrix for in-house and contract-pharmacy claims, and check whether any separate reporting obligations remain. For more on submission controls, read 7 mistakes to avoid with multi-portal 340B data submissions.
Escalate early and document each step
When a claim is incomplete, delayed, or disputed, follow a consistent escalation path:
- Contact the manufacturer first. Provide the claim or transaction ID, NDC-11, dispense date, submission and completion dates, status history, and relevant documentation.
- If the platform issue remains unresolved, contact Beacon support at support@beaconchannelmanagement.com or 1-878-788-8907. Save the case number and response.
- If the issue remains unresolved after good-faith efforts, contact HRSA at 340BPricing@hrsa.gov, with a concise timeline and records of your prior escalation.
Keep a written log of each contact, response, and next step. That record helps your team manage exceptions and explain the status of pending dollars to leadership.
A weekly reconciliation process does not need to be complicated. It needs clear ownership, reliable claim-level data, early exception alerts, and a repeatable link between dispense, submission, and cash received. GapRx supports covered entities with rebate navigation, claims validation, compliance oversight, and analytics. Schedule a TidyCal strategy call to review your entity’s workflow and prepare for the 2027 transition.
This article is for general informational purposes and is not legal advice. Confirm current HRSA requirements and manufacturer-specific instructions before implementing your workflow.
Sources
[^1]: HRSA, Notice Regarding 340B Rebate Model Pilot Program, August 3, 2026.
[^2]: HRSA, Revised 340B Rebate Model Pilot Program; see also the HRSA 340B Rebate Model Pilot Program page