In This Issue...
Jeff Weighs In
Advocacy and Legal Update
340B Reform Efforts Pick Up Steam
by Artemis Policy Group
This summer has seen a sharp uptick in Congressional attention to 340B policy. Senator Cassidy, outgoing Chairman of the Senate Committee on Health, Education, Labor and Pensions, released draft 340B legislation for public comment. A reconstituted Senate “gang of 6” introduced an updated version of the “SUSTAIN 340B Act” (S. 5244). Meanwhile, on the House side, four lawmakers have introduced their own bill: H.R. 9599, the “SECURE 340B Act.”
Briefly, the various bills:
- Give manufacturers the choice of requiring rebates or discounts, unless covered entities meet certain conditions (Chairman Cassidy discussion draft).
- Prohibit rebates for four years and prohibit limits on CE use of contract pharmacies – but require covered entities to submit data to a new data clearinghouse (SECURE Act, H.R. 9599).
- Reaffirm the original intent of the 340B program (clarifying that the program requires manufacturers to provide point-of-purchase discounts, rather than rebates), and codify covered entities’ authority to use contract pharmacies, while also providing for audits and reporting, and establishing a 340B data clearinghouse (SUSTAIN 340B Act, S. 5244).
A more detailed summary of the three bills – and Administration 340B activities – can be found at this LINK.
While none of the 340B reform bills are moving fast toward passage, the Hemophilia Alliance is of course keeping close watch on all these developments. At a very high level, we can report that each bill has some good policies and some minor to major areas of concern for HTCs. In June and July, Alliance staff met with some of the Congressional offices that are driving reform efforts. We provided information about how HTCs use 340B, the unique characteristics of HTCs, HTC reporting requirements, how HTCs can utilize 340B program income, and the importance of maintaining HTC ability to participate in the program. The Hemophilia Alliance will continue to engage with the respective bill sponsors to explain our concerns and recommend changes to improve the problematic sections of the bills. The Alliance’s 2026 Hill Day this September will be an ideal time to reinforce these messages with lawmakers.
Funding for Fiscal Year 2027
Senate and House Pass Competing Short-term Funding Bills
Trying to prevent a fight over federal spending and potential partial government shutdown before the mid-term election, the Senate passed a continuing resolution (CR) in early August to fund the government at current levels from the October 1, 2026, start of fiscal year 2027 through December 11th. The Senate bill would also prevent a controversial new rule about government grants from taking effect before December. Because the Senate bill differs from the House-passed CR, the two chambers will have to work out their differences when they return from recess in September in order to enact a spending measure.
House Passes Budget Resolution
On July 22, 2026, the House of Representatives passed a Fiscal Year (FY) 2027 budget resolution for a third reconciliation package. The resolution provides budget instructions for House committees overseeing many government programs (e.g., defense, intelligence, and agriculture) – but it provides no instructions to the committees with jurisdiction over health insurance, Medicaid, or Medicare (Energy and Commerce Committee and Ways and Means). As a result, the budget resolution does not directly affect federal health policy. The bill now goes to the Senate, where its passage is unclear. If it passes, then Congress needs to separately write and pass the bill, so there are steps still to go! Some in Congress are pushing for a 4th reconciliation package this Congress to tackle issues related to fraud, waste, and abuse in health care programs but there likely won’t be sufficient time to pursue another bill.
More on Medicaid Work Requirements
We have previously reported on guidance released by the U.S. Centers for Medicare and Medicaid Services (CMS) regarding State implementation of the work reporting requirements contained in last year’s One Big Beautiful Bill Act. In late July, the Hemophilia Alliance together with NBDF and other bleeding disorders partners filed comments responding to the guidance, urging CMS to broaden its unduly narrow exemptions for people with “serious or complex medical conditions.” Bleeding disorders are undeniably “serious or complex” and the loss of coverage for people living with these conditions would have devastating consequences for their health. The Hemophilia Alliance is working to develop toolkits and other resources for HTCs to use as the Medicaid work reporting requirements come online.
Policy Changes to HHS Salary Rate Limits
Hemophilia Treatment Centers should remain cognizant of restrictions related to payment of employees under their grant. Every year, Congress sets a limit on how much salary a person can be paid with HHS grant or cooperative agreement funds. This salary limit applies to sub-awards and subcontracts. It also applies to all individuals working on the award, including staff, contractors, or consultants.
Under the rules, recipients cannot use award funds to pay anyone more than the Executive Level II rate which is set at $228,000 for 2026. Importantly, in recent years, HHS updated the HHS Grants Policy Statement so that the salary limit applies to both direct and indirect costs for HHS awards. For staff whose salary rates exceed Executive Level II amount, recipients may pay the excess from non-federal funds. Please reach out to the Hemophilia Alliance and to your Regional leadership if you have questions regarding this policy.
Member and Community Relations Update
Understanding the Differences between HANS Agreements and Single Case Agreements
by Jennifer Borrillo and the MCR Team
Hemophilia Alliance Network Services (HANS) was created in January 2017 by the Hemophilia Alliance to facilitate contracting opportunities between insurers, PBMs, stop-loss carriers, self-funded employers and Hemophilia Treatment Centers (HTCs) efficiently across geographic areas for high-cost bleeding disorder medications. HANS is a subspecialty national network of HTCs organized as a preferred provider organization (PPO) network, which aims to:
- Help HTCs remain in or gain access to payer and PBM networks by delivering competitively priced bleeding disorder medications and integrated best-in-class clinical and pharmacy services with regional and/or national coverage;
- Align payer needs with HTCs in areas such as billing, collection, reporting, and competitive price points under broader group terms; and
- Reduce administrative burden by providing a streamlined method for payers to contract for bleeding disorder medication distribution and clinical care without contracting with each individual HTC.
HANS agreements thus play a role similar to single case agreements (SCAs) and letters of agreement (LOAs), insofar as all aim to connect patients, payers, and HTCs for the provision of high-quality care and cost-effective pharmacy services. But HANS agreements are designed to establish permanent in-network status, avoiding the need for temporary one-off exceptions. HANS streamlines payer and provider integration to bypass case-by-case administrative burdens and negotiates volume or blanket arrangements rather than individual patient approvals.
To date, most HANS arrangements have been local or regional rather than nationwide in scope. We are excited to report that HANS recently has executed two broader national PBM contracts – and continues to discuss future opportunities with additional larger payers and PBMs.
As noted in the February 2026 newsletter, SCAs continue to be a valuable path forward for out-of-network HTCs to resolve individual coverage issues. An SCA is a one-time contract between a payer and/or employer and an HTC and its pharmacy that sets specific rates and rules to cover a single patient to secure more reasonable pricing for a specific drug or drugs for a specified period. Your HTC does not have to be signed onto the HANS network to engage in an SCA opportunity.
A High-Level Comparison of SCAs and HANS Opportunities
To summarize, HANS opportunities are network-based contracting arrangements that connect participating HTCs with regional and national payers through a standardized PPO structure, reducing administrative burden while expanding access and contracting opportunities. SCA opportunities are broker or HTC-led one-off opportunities — individualized, employer-specific arrangements that begin with a savings inquiry and may result in an SCA for one or more members. Together, both HANS and SCAs are approaches that allow the Hemophilia Alliance to support both immediate employer-specific savings opportunities and broader strategic payer partnerships for HTC sustainability. For additional details on HTCs’ roles with respect to each category of opportunities, please click here.
Remember the Hemophilia Alliance does not charge members for either of these services and WE WORK FOR YOU!!
Administration and Operations Update
New This Fall: Event Resources in One Convenient Hub!
by The Admin & Ops Team
Team Alliance is excited to announce the launch of the Attendee Hub for our Fall Members Meeting. The Attendee Hub is designed to be your event’s digital home, bringing all event resources into one convenient platform accessible from your computer and mobile device. It will include the event schedule, speaker information, meeting materials, networking opportunities, and important updates.
Whether you’re planning your agenda, connecting with fellow attendees, participating in live Q&A sessions, or accessing presentation materials, the Attendee Hub makes it easy to get the most out of your meeting experience. No more searching through emails or juggling multiple apps. Everything you need is available in one place.
In the coming months, you’ll see Attendee Hub used across many Hemophilia Alliance events, making it easier than ever to access resources, receive event updates, provide feedback, and network with colleagues and peers.
Please note: Access to the Attendee Hub is available exclusively to staff and attendees from Hemophilia Alliance member HTCs and other approved event participants.
MPBA 2027 Registration Now Open!
Please plan to join us January 24-26, 2027, in Salt Lake City, Utah, for the next Medical Providers & Business Administrators (MPBA) Meeting. The Hemophilia Alliance is once again bringing together key HTC strategic leaders, including medical providers (MPs), business administrators (BAs), and pharmacy leaders where applicable. Together, participants will explore emerging challenges and opportunities, share innovative practices, and shape the future of HTC operations and patient services.
The meeting begins with an optional pre-conference featuring:
- HTC & 340B Fundamentals: Grounding your team in the essentials
- Pharmacy Models and Billing Practices: Understanding HTC pharmacy models, billing practices and contract pharmacy relationships.
The main agenda features timely discussions on:
- HTC sustainability and lessons learned
- Hot topics in compliance
- Novel therapy implementation from clinical, operational, and financial perspectives
- Staff retention and engagement strategies
- Payer trends and the evolving role of single case agreements
- The HTC pharmacist’s role in collaborative care
- Advocacy and policy updates impacting HTCs
- Business planning and organizational success
- Networking and peer-to-peer collaboration across disciplines
A recent attendee captured the value of the meeting best:
“The MPBA Meeting has become one of the most valuable gatherings I attend. The depth of discussion, practical strategies, and open collaboration help me return to my HTC with fresh ideas for the path forward.”
— MPBA Past Attendee
If you are a clinical, administrative, or pharmacy leader with strategic or financial decision-making responsibilities at your HTC, this meeting is designed for you. Space is limited, and applications will be reviewed to ensure the meeting remains focused on HTC leadership and strategic decision-makers. Register by September 30 or before capacity is reached.
Annual Member Dues – Past Due!
Annual membership dues invoices were distributed in February. While many members have submitted payment, a significant number of accounts remain outstanding.
To maintain good standing and continue receiving the full benefits of Hemophilia Alliance membership, payment of your annual dues is expected at your earliest convenience. Failure to remit payment may impact your organization’s access to membership benefits and services.
If you have questions regarding your invoice or payment status, please contact Theresa Parker at theresa@hemoalliance.org or 727-688-2568.
Notes From The Community
VWD Connect Foundation Workshop – October 9-11, 2026
HTC clinicians (doctors, nurses, social workers, physical therapists, genetic counsellors, etc.) are invited to register for a Provider Education Workshop on severe von Willebrand Disease, offered by the VWD Connect Foundation. The workshop will be offered in West Palm Beach, Florida, from October 9-11. Please see the flyer for additional details.
Have a story you want to share or a topic you would like us to cover?