As part of the 2026 and 2027 Ohio budget bill, Ohio legislators included annual reporting requirements for 340B Program Covered Entities. This legislation, which was signed into law on June 30, 2025, will require Covered Entities to submit data by July 1, 2026. The bill indicates that the Ohio Department of Health (ODH) will collect these reports and post the information to its website. This legislation aims to enhance transparency within the 340B Program in Ohio. A summary of the key provisions is below; however, ODH has not yet released any guidance related to this reporting.
- Tracking and reporting detailed 340B Program data: Covered Entities must be prepared to accurately track and report specific data:
- Total acquisition costs and payments for 340B Program drugs, sorted by payer type
- Total prescriptions filled overall and at contract pharmacies, and the percentage of the total that are 340B Program drugs, sorted by payer type
- Total 340B Program payments made to contract pharmacies, third-party administrators, or others
- Accounting of expenditures from 340B Program profits to include “all programs, services, and equipment funded or purchased”
- Total number of contract pharmacies
- Ensuring data accuracy and completeness: As stated above, ODH will publicly post the reported information on its website. The accuracy and completeness of the data submitted by each Covered Entity will be crucial to avoiding potential issues and accurately telling the 340B Program story in Ohio.
- Understanding the scope of required information: Covered Entities should carefully review the specific required data points once they are published by ODH to be prepared to gather and submit this information.
- Preparation and review: Covered Entities should begin taking steps to ensure that their organization is prepared to meet the reporting requirements by the annual July 1st
Questions? We’re here to help.
Blue & Co. is closely tracking information releases from ODH and will share more guidance as information is available. 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
