03/30/2026 – RWC-340B Letter to Novo Nordisk CEO Objecting to Policy Requiring Covered Entities to Submit Claims-Level Data

RWC-340B sent a letter to Novo Nordisk’s CEO on March 26, 2026, objecting to the drug manufacturer’s policy requiring covered entities to submit claims-level data for all 340B utilization.

Novo Nordisk’s policy, effective April 1, 2026, requires covered entities to submit claims-level data for “all 340B dispenses,” regardless of whether an entity uses contract pharmacies.  Covered entities have 45 days from the date of dispense to submit this data, creating a deadline of May 16, 2026, for covered entities to comply.  If a covered entity fails to provide timely, complete, and accurate data for all 340B dispenses, the company may cancel 340B pricing for the entity.

Novo Nordisk’s policy is almost identical to Eli Lilly’s claims data policy, which went into effect on February 1, 2026 and which RWC-340B opposed in a February 18, 2026 letter to the drugmaker.

Like RWC-340B’s letter to Eli Lilly, the letter to Novo Nordisk details how Novo Nordisk’s policy is an unprecedented and unequivocal violation of federal law.  Novo Nordisk violates the 340B statute and its pharmaceutical pricing agreement with the Secretary of Health and Human Services by overcharging covered entities that refuse to acquiesce to Novo Nordisk’s conditions.  Novo Nordisk also violates several state laws, as its policy does not include exceptions for states with laws prohibiting manufacturers from requesting data from covered entities.  Finally, RWC-340B’s letter details the significant administrative costs the policy will impose on covered entities and how the policy undermines RWCs’ ability to care for the patients they serve.

RWC-340B copied HRSA on the letter it sent to Novo Nordisk and met with the agency last week to discuss concerns with both Eli Lilly and Novo Nordisk’s policies.  RWC-340B will continue to engage aggressively with HRSA, CMS, and drug manufacturers to defend the integrity of the 340B program for the patients and communities we serve.