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Indiana SB 118: New 340B Reporting Requirements for Covered Entities

Indiana Senate Bill 118, which went into effect on July 1, 2025, requires certain Covered Entities participating in the federal 340B Program to annually report data regarding their program to the Indiana Department of Health (IDOH).  The Senate Bill indicates that IDOH will aggregate all the data, submit a report to the Legislative Council, and publicly post the report on its website.  This legislation is intended to create greater transparency within the 340B Program in Indiana.  A summary of the Senate Bill’s main points is below; however, IDOH has not yet released any guidance related to this reporting.

Indiana Senate Bill 118 requires a proactive approach to data collection and reporting, as outlined below.

  • Tracking and reporting detailed 340B Program data: Covered Entities must be prepared to accurately track and report specific data related to the acquisition cost of 340B Program medications, payments received for dispensing 340B Program medications, all payments made to outside entities related to the 340B Program, utilization of 340B Program savings, and other related expenses.
  • Ensuring data accuracy and completeness: IDOH will use the submitted data to compile a comprehensive report that will ultimately be publicly available for review. Accuracy and completeness of the data submitted by each Covered Entity will be crucial to avoid potential issues and to accurately tell the 340B Program story in Indiana.
  • Understanding the scope of required information: Covered Entities should carefully review the specific data points required for submission once they are available to be prepared for submission and avoid any potential penalties.
  • Review and strengthen compliance programs: Covered Entities should ensure that their organization has robust internal controls and procedures in place to meet the reporting requirements by the annual April 1st deadline.

Questions? We’re here to help.

Blue is closely tracking information releases from IDOH and having ongoing discussions with local industry leaders. Once additional details on this reporting legislation are available, Blue will share this information and be available to assist Covered Entities with meeting these new requirements. If you have any questions in the interim, please do not hesitate to reach out to one of our 340B ACE-certified advisors listed below.

Kyle Smith, CPA, 340B ACE, Director

Jason Prokopik, PharmD, 340B ACE, Senior Manager

Alyssa Kramer, PharmD, 340B ACE, Manager

Kelly Kuhn, 340B ACE, Senior Pharmacy Consultant

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