Contract Pharmacy Restrictions
The 340B program has undergone significant transformation since its inception, particularly with the explosive growth of contract pharmacies following the 2010 HRSA guidance. This evolution has created friction with pharmaceutical manufacturers, leading to a wave of restrictive policies limiting how covered entities—especially hospitals—can use contract pharmacy networks to access 340B discounts.
These restrictions vary significantly between manufacturers and often delineate different rules for hospitals and grantees. Legal battles and state-level interventions have added further complexity, creating a fragmented and rapidly changing compliance landscape.
View and Download Current Manufacturer Policies
Access the latest manufacturer-issued policy documents governing 340B contract pharmacy restrictions. These files are regularly updated and include the official guidance, designated product lists, and enforcement mechanisms. Simply click the hyperlinks below to view and/or download the official letters.
AbbVie requires the submission of 340B contract pharmacy claims data to the 340B ESP™ platform to be eligible for 340B pricing.
For Hospital Entities: In addition to submitting data, hospital covered entities must designate a single contract pharmacy location for all AbbVie medicines.
For Grantee Entities: Grantees are required to submit claims data via 340B ESP™ but are not limited to a single contract pharmacy designation.
Alkermes will provide 340B pricing for its drugs to only one designated contract pharmacy location per covered entity. Covered entities that do not have their own in-house pharmacy are eligible for this single designation. To be eligible, the entity must register and make its designation on the 340B ESP™ platform. No restrictions for entity-owned pharmacies.
AstraZeneca will recognize only a single designated contract pharmacy per covered entity. This applies to all 340B covered entities, which are also required to submit claims data for that designated pharmacy to the 340B ESP™ platform.
Amgen will ship 340B-priced products to only one contract pharmacy location per 340B hospital. This policy applies specifically to hospital covered entities, which must use the 340B ESP™ platform to make their designation.
Astellas will no longer provide 340B pricing for medicines shipped to an unlimited number of contract pharmacies.
Exception: A covered entity that does not have an in-house pharmacy may designate a single contract pharmacy location.
Requirement: To be eligible for this exception, the entity must register on the 340B ESP™ platform and submit claims data for the designated pharmacy.
Bausch Health will no longer offer 340B pricing for any of its products shipped to contract pharmacies.
Exception: An exception is available for covered entities that do not have an in-house pharmacy; they may designate a single contract pharmacy.
Requirement: This exception requires the entity to register and submit claims data through the 340B ESP™ platform.
Bausch and Lomb - June 5, 2024
Bausch and Lomb will not offer 340B pricing on its products shipped to contract pharmacies.
Exception: A limited exception is available for a covered entity that does not have its own in-house pharmacy, which allows for the designation of a single contract pharmacy.
Requirement: To be eligible, the covered entity must register and make its designation on the 340B ESP™ platform.
This policy applies to hospital and grantee covered entities. Biogen will provide 340B pricing to a single contract pharmacy per eligible covered entity. Registration and designation must be completed through the 340B ESP™ platform.
Boehringer Ingelheim - November 1, 2024
Boehringer Ingelheim requires covered entities to provide claims data via the 340B ESP™ platform for their 340B prescriptions filled at contract pharmacies. The policy does not appear to limit the number of contract pharmacies an entity can use, provided the data is submitted.
Bristol Myers Squibb - July 10, 2025
Bristol Myers Squibb (BMS) requires covered entities to provide claims data for 340B-discounted medicines dispensed by their contract pharmacies. This data must be submitted through the 340B ESP™ platform. If an entity provides the data, BMS will honor 340B pricing for all contract pharmacy locations of that entity.
Bayer will no longer provide 340B pricing on its products shipped to contract pharmacies.
Exception: Covered entities without an in-house pharmacy may designate a single contract pharmacy.
Requirement: The designation must be made on the 340B ESP™ platform, and the entity must provide claims data for the designated pharmacy.
Eisai will not offer 340B pricing to contract pharmacies.
Exception: A covered entity that does not have an in-house pharmacy may designate a single contract pharmacy.
Requirement: The entity must register on the 340B ESP™ platform to make its designation.
Eli Lilly will no longer offer 340B pricing for any of its products shipped to contract pharmacies.
Exception: An exception is granted to covered entities that do not have an in-house pharmacy, allowing them to designate a single contract pharmacy.
Requirement: To qualify, the entity must register and designate its pharmacy through the 340B ESP™ platform.
EMD Serono will not offer 340B pricing on shipments to contract pharmacies.
Exception: A limited exception is available for covered entities without an in-house pharmacy, which allows them to designate one contract pharmacy.
Requirement: Eligibility requires registering and submitting claims data via the 340B ESP™ platform.
This policy applies to federal grantee covered entities. To receive 340B pricing for its products dispensed at contract pharmacies, grantees must submit claims data through the 340B ESP™ platform.
Gilead will only provide 340B pricing on its HIV prevention agents to a single designated contract pharmacy per covered entity. Covered entities must use the 340B ESP™ platform to make this designation.
GlaxoSmithKline - July 18, 2025
GSK will not provide 340B pricing on products shipped to contract pharmacies.
Exception: A covered entity without an in-house pharmacy may designate a single contract pharmacy.
Requirement: The entity must register and provide claims data for the designated pharmacy via the 340B ESP™ platform.
Genentech offers two options for covered entities regarding contract pharmacies:
Continue to purchase products at WAC for their contract pharmacies.
Provide claims data for their designated contract pharmacies via the 340B ESP™ platform to receive 340B pricing.
Incyte will no longer provide the 340B discount for any of its products dispensed by contract pharmacies, but offers an alternative voluntary distribution model. To continue accessing 340B pricing for their contract pharmacies, covered entities must provide limited claims data for those prescriptions through the 340B ESP™ platform.
Johnson & Johnson - August 5, 2025
This policy applies to grantee covered entities. J&J will not provide 340B pricing to contract pharmacies located in states that have enacted laws prohibiting such restrictions. For grantees in all other states, J&J requires the submission of claims data via 340B ESP™ to continue using contract pharmacies.
Jazz Pharmaceuticals will not facilitate bill to/ship to replenishment orders for any of its products to contract pharmacies.
Exception: An exception is available for covered entities that do not operate their own in-house pharmacy, which allows them to designate one contract pharmacy.
Requirement: The covered entity must register and make its designation on the 340B ESP™ platform.
This policy applies specifically to the drug TYVASO DPI®. Liquidia will only honor 340B pricing for TYVASO DPI® at a single designated contract pharmacy. This applies to covered entities without an in-house pharmacy capable of dispensing the drug.
Requirement: The designated pharmacy must be part of the TYVASO DPI® limited distribution network. The covered entity must register on the 340B ESP™ platform and submit claims data for the drug when dispensed by the designated pharmacy.
This policy applies to hospital covered entities. Merck requires these hospitals to provide claims data for prescriptions filled by their contract pharmacies through the 340B ESP™ platform. The policy does not appear to limit the number of contract pharmacies if data is submitted.
This policy applies to hospital and grantee covered entities. Novo Nordisk will only honor 340B pricing at a single designated contract pharmacy per covered entity for hospitals (does not apply to grantees). This designation requires registration and claims data submission through the 340B ESP™ platform.
The policy for Novartis has two components based on entity type:
For Hospital Entities: To receive 340B pricing at contract pharmacies, hospitals must provide claims data for those pharmacies through the 340B ESP™ platform.
For Federal Grantees: Grantees are exempt from this requirement and may continue to use contract pharmacies without submitting claims data.
Organon will not provide 340B pricing on its products to contract pharmacies for hospital covered entities. Federal grantees are not subject to this restriction.
This policy applies to hospital covered entities. Pfizer will only provide 340B pricing to a single designated contract pharmacy per hospital. The designation must be made, and claims data must be submitted, through the 340B ESP™ platform.
Sandoz will no longer voluntarily offer 340B pricing for any of its products shipped to contract pharmacies.
Exception: A limited exception is available for a 340B covered entity that does not have an in-house pharmacy, which allows them to designate one contract pharmacy.
Requirement: To be eligible, the entity must register on the 340B ESP™ platform and submit claims data for 340B-discounted drugs dispensed by their designated pharmacy.
This policy applies to hospital covered entities. Sumitomo will not provide 340B pricing on its products shipped to contract pharmacies.
Exception: An exception is available for hospitals that do not have an affiliated pharmacy within a 40-mile radius of the 340B parent site. These hospitals may designate a single contract pharmacy.
Requirement: To be eligible for the exception, the hospital must register on the 340B ESP™ platform and provide claims data.
This policy applies to hospital and grantee covered entities. Sanofi will only provide 340B pricing to a single contract pharmacy location per covered entity. This requires designation and claims data submission via the 340B ESP™ platform.
Sobi will not provide 340B pricing for its medicines shipped to contract pharmacies.
Exception: A covered entity that does not have a wholly-owned pharmacy within 40 miles of the parent site may designate a single contract pharmacy.
Requirement: To be eligible, the entity must register and submit claims data through the 340B ESP™ platform.
Takeda will only ship 340B-priced products to a single contract pharmacy location per covered entity. The policy applies to all covered entities, and designation must be made via the 340B ESP™ platform.
Teva will no longer offer 340B pricing to contract pharmacies.
Exception: Covered entities without an in-house pharmacy may designate a single contract pharmacy.
Requirement: Designation requires registration and data submission via the 340B ESP™ platform.
This policy applies to hospital covered entities. UCB will only recognize a single contract pharmacy for each hospital. The designation must be made through the 340B ESP™ platform.
Vertex will only provide its medicines at a 340B price to a single contract pharmacy designated by a covered entity. The designation requires registration and claims data submission via the 340B ESP™ platform.
Viatris will not offer 340B pricing to contract pharmacies.
Exception: Covered entities without an in-house pharmacy can designate a single contract pharmacy.
Requirement: The designation must be made on the 340B ESP™ platform.
