Compliance Corner March 2026
HRSA issued a Request for Information (RFI) to gather input from interested parties regarding the potential use of rebates to effectuate the ceiling price under the 340B Program, including the standards and procedures that should govern the approval of manufacturer rebate plans and the impacts on all stakeholders. This RFI seeks comments on whether HRSA should implement a rebate model under the 340B Program and how best to operationalize any such rebate framework for stakeholders. The information collected through this RFI will assist HRSA in evaluating the operational, financial, and access to drugs for patients of a rebate model on covered entities, manufacturers, and other stakeholders across the drug supply chain.
Please review the RFI and provide your feedback by Thursday, March 19.
Source: HRSA
The Bureau of Primary Health Care Office of Health Center Program Monitoring’s (OHCPM) new operating model has been implemented. They have re-introduced the Project Officer (PO) role, allowing them to better focus on the unique needs of health centers. BPHC will support oversight through four divisions—Eastern, Central, Western, and Strategic Support. Together, these divisions will provide consistent, strategic, and coordinated engagement.
Each health center has been assigned a dedicated PO to serve as its key programmatic point of contact. Your PO has already sent an introductory email to your designated point of contact. BPHC encourages health centers to continue using the BPHC Contact Form for general questions pertaining to the health center program. For time-sensitive, urgent matters pertaining to your health center grant, please contact your PO.
Source: BPHC
See the slides from the Thursday, February 26, BPHC Program Updates webcast. Here are other highlights from the webcast:
Source: BPHC
The UDS report submission deadline was Sunday, February 15, and Health Center Program Uniform Data System (UDS) reviewers will be validating UDS reports through Tuesday, March 31. The UDS reviewers will help health centers explain or correct the 2025 UDS data they reported. UDS reviewers will send communication and requests for data changes through EHBs. Health center staff should communicate directly with the assigned UDS reviewer to address their questions. Final, corrected 2025 UDS submissions are due no later than Tuesday, March 31. HRSA will not accept changes to the UDS after this deadline.
Source: HRSA
Program Assistance Letter (PAL) 2026-01 Now Available
Please be advised that the Calendar Year (CY) 2027 Requirements for Federal Tort Claims Act (FTCA) Coverage Program Assistance Letter (PAL) 2026-01 is now available. PAL 2026-01 outlines the requirements and process that health centers must follow to submit their:
The PAL includes updated application instructions. Please review the document carefully to assist health centers with ensuring compliance with all submission requirements. View the document HERE.
Source: MPCA
Registration is open for HRSA’s 2026 Federal Tort Claims Act (FTCA) Deeming Application Clinic. Health centers will have the opportunity to engage in practice, hands-on learning with HRSA risk management subject matter experts. Presenters will provide a comprehensive overview of the FTCA deeming application and key considerations for submitting a strong application. This three-day virtual clinic is a great opportunity to engage directly with experts, ask questions, and prepare your team to complete your FTCA 2027 Deeming Application.
Wednesday, March 25 – Friday, March 27 (Rescheduled Dates)
1:00 p.m. ET
Source: HRSA
Regulators are no longer satisfied with documentation alone; they want evidence that your compliance program actively prevents, detects, and corrects risk. Investigators expect to see how issues are identified early, investigated thoroughly, corrected effectively, and monitored over time. Boards demand measurable insight, and leadership needs confidence that exposure is managed before it becomes a liability. The standard has shifted from activity to impact.