Mapping the 340B Transparency Landscape

Sep 17

2 min read

As 340B revenues have soared, hospitals are under increasing scrutiny for their use of the program. In response, an increasing number of states - red and blue alike have responded, passing 340B transparency measures to find out exactly where the money is going.

Minnesota and Washington were the first of the transparency push, enacting reporting requirements in 2023. The Washington State Health Care Authority (HCA)’s first report in December 2024 found that some Medicaid providers under the 340B program were reimbursed above their self-reported costs. In Minnesota, estimates from the 2026 report by the Minnesota Department of Health (MDH) indicated that Minnesota 340B hospital revenue more than doubled to $1.34 billion in 2024. That figure represents more than $1 billion more than Minnesota hospitals spent on uncompensated care that same year, providing the clearest state-level evidence yet that despite the program's intent, 340B revenues are not being utilized to provide care to the patients the program was intended to serve.

More states are set to follow. Over the coming months, several other states are expected to release aggregated reporting analysis, including:

Ohio: Covered entity transparency data expected to be released publicly by October 1, 2026
Idaho and Indiana: Covered entities were required to submit data in April 2026 with statewide reports expected from the Idaho Office of the State Controller and Indiana Department of Health (IDOH) by November 15, 2026.
Colorado: Submission data was required by July 1, 2026, and will be incorporated into the Colorado Hospital Community Benefit report expected in January 2027.
Vermont: While there is no standalone state-aggregated summary report, hospital reporting data is due annually to the Green Mountain Care Board (GMCB) by January 31st, 2027.

The data available today represents only the beginning. The next twelve months will produce an unprecedented body of state-level evidence on how 340B revenues are generated, captured, and most importantly utilized for the patients the program was intended to serve. Each new report adds to a growing public record as policymakers, payers, and patient advocates continue to debate reforms to the 340B program at the state and federal level.