Thomas Johnson

Thomas Johnson is Executive Director of the Alliance to Save America’s 340B Program (ASAP 340B), with three decades of experience in healthcare policy and nonprofit leadership. He previously served as President and CEO of Medicaid Health Plans of America and the DC Hospital Association, and has held senior roles with Medicaid health plans, policy consulting firms, and regional health organizations. Johnson has also served on numerous boards, including as chair of the Sickle Cell Disease Association of America.

Congress created the 340B Drug Pricing Program to allow certain hospitals to buy drugs at deep discounts and use those savings to help lower-income, vulnerable patients access care. While its stated mission remains vital—particularly as communities grapple with access and affordability challenges—the exponential growth of the program has raised serious questions about whether benefits are consistently reaching patients and whether the program is being managed at a scale that reflects its current cost and complexity.

Despite dramatic expansion over the past 34 years, many rural and underserved hospitals continue to face significant financial pressures and closures, underscoring concerns about whether 340B is operating as Congress originally intended or delivering the patient-focused outcomes policymakers expect. 

If the program is growing rapidly, costs are increasing, and there is little evidence that savings are reliably improving access for vulnerable patients, the conclusion is clear: it is time to modernize and strengthen 340B through renewed congressional oversight and greater transparency and accountability That’s not radical. It’s responsible.

Reform does not mean ending the program. The 340B program continues to serve as a lifeline for many hospitals and clinics. However, outdated oversight structures and limited transparency have allowed it to drift from its original, patient-focused intent—a concern increasingly shared not just by policymakers, but by a diverse coalition of patient advocates, civil rights organizations, and community health leaders, including ASAP 340B, the coalition I lead. 

The Congressional Budget Office’s 2025 report highlights the magnitude of this shift. As the first comprehensive congressional analysis of the program since 1992, it found that spending on drugs purchased through 340B grew from $6.6 billion in 2010 to $43.9 billion in 2021—an average annual increase of roughly 19 percent. That growth far outpaces overall prescription drug spending, prompting questions about whether existing oversight tools are sufficient. Structural changes across the healthcare system have reshaped 340B participation, yet accountability has not kept pace.  

At the program’s outset, roughly 90 facilities participated. Today, more than 12,000 covered entities and over 50,000 affiliated outpatient sites are involved in some way. Much of this growth reflects consolidation, hospital acquisition of physician practices, and policies that allow large systems, often in urban areas, to qualify for discounts intended for a narrower safety-net population. In practice, that can mean the discounts follow the footprint of a health system, not the needs of a patient. These shifts make it increasingly important for Congress to reexamine eligibility, data reporting, and accountability requirements. 

This evolution is the central issue facing 340B today: incentives no longer consistently align with patient-centered care. The current structure can steer care toward in-system pharmacies and services even when access or affordability for low-income patients does not materially improve. When incentives drift, patients pay the price. Most concerning is the near-total absence of transparency requirements that would allow Congress to assess outcomes and protect patient and taxpayer interests.  

There is no consistent federal requirement that participating entities report how 340B savings are used. Policymakers and the public often assume discounts are benefiting patients, despite limited data to confirm either assumption. That gap has prompted equity-focused and community-based advocates to call for reforms ensuring savings reach underserved patients rather than being absorbed into broader system revenue.  

The goal is not to assign blame. Providers are largely operating under existing rules. The responsibility lies with policymakers to update those rules by implementing reasonable oversight, reporting, and accountability standards reflecting how healthcare has evolved since 1992. Bipartisan coalitions such as the Alliance to Save America’s 340B Program—which unites several important stakeholder perspectives—are working toward that goal. 

Above all, 340B must serve patients. Once a bipartisan commitment to vulnerable communities, the program has grown dramatically while drifting from that purpose. With renewed congressional attention, modern oversight tools, and transparency requirements proportionate to its scale, lawmakers can ensure 340B once again delivers on its promise.

Thomas Johnson is Executive Director of the Alliance to Save America’s 340B Program (ASAP 340B), with three decades of experience in healthcare policy and nonprofit leadership. He previously served as President and CEO of Medicaid Health Plans of America and the DC Hospital Association, and has held senior roles with Medicaid health plans, policy consulting firms, and regional health organizations. Johnson has also served on numerous boards, including as chair of the Sickle Cell Disease Association of America.

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