Reference guide updated September 8, 2026.
This is a planning framework, updated from the July 2025 article. The scenarios below are possibilities for discussion, not forecasts of legislation, drug prices or program eligibility.
Test three operating scenarios
- More standardized requirements: consider the value of a consistent evidence register, repeatable transaction reviews and clear data ownership.
- More varied restrictions: examine how product, manufacturer, pharmacy and jurisdiction differences would affect staff workload and access.
- More emphasis on demonstrated impact: assess whether your organization can explain how program resources support services using its own records.
Use your own assumptions
Model costs and service decisions using documented organization-level assumptions. Do not treat a national savings estimate, a sample scenario or an unreviewed policy summary as your clinic’s projected margin.
Prepare actions that remain useful across scenarios
Keep program records organized, document responsibility for source review, and make follow-up on findings visible. HRSA’s current program-integrity page is a source for the agency’s actual oversight process. HRSA program integrity.
The Impact Profile Builder can help organize your service narrative. Its calculations use your supplied assumptions and do not certify compliance or predict future returns.