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Navigating Gilead's Latest Update: A Sour Start for 2024

Updated: Jan 5

ESP Restrictions 1.5.24
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The 340B Drug Pricing Program, known for its intricate dynamics and evolving landscape, has encountered its first significant update of the year from Gilead. Starting the year with this update sets a tone that many covered entities may find challenging. While Gilead aims to bolster transparency and program integrity, the new guidelines present increased restrictions and complexities.

Gilead's Contract Pharmacy Integrity Initiative Update

Key Highlights:

  1. First Update of the Year: Gilead's Contract Pharmacy Integrity Initiative is the inaugural significant update of 2024, marking the beginning of the year with stringent regulations for covered entities.

  2. Scope and Objective: Primarily targeting its Branded HCV Products, such as Epclusa®, Harvoni®, Sovaldi®, and Vosevi®, Gilead's initiative intensifies efforts against duplicate discounting and diversion.

  3. Mandatory Data Submission: Effective January 30, 2024, covered entities face mandatory claims level data submission requirements for Gilead's Branded HCV Products dispensed through wholly-owned contract pharmacies.

  4. Voluntary Submission: Entities retain the option for voluntary claims level data submission for products dispensed via in-house or designated single contract pharmacy locations.


  • Wholly-Owned Contract Pharmacies: The mandatory data submission for wholly-owned contract pharmacies adds a layer of complexity, especially given the early timing of this update in the year.

The Continual Increase of Restrictions

A Broader Perspective:

The initiation of 2024 with Gilead's update amplifies the ongoing trend of increasing restrictions within the 340B program. Pharmaceutical companies' intensified efforts towards transparency result in stricter regulations, setting an early precedent for the year.

The Louisiana and Arkansas Exception: An Absence

The absence of exceptions for Louisiana and Arkansas in Gilead's update further accentuates the challenging tone set at the beginning of the year. These states, characterized by distinct healthcare landscapes, face additional complexities due to the overarching nature of the update.


Gilead's Contract Pharmacy Integrity Initiative, as the first significant update of 2024, sets a challenging tone for covered entities within the 340B program. While aiming to enhance transparency and program integrity, the update introduces increased restrictions and complexities, with no specific exceptions for states like Louisiana and Arkansas. As covered entities navigate these developments, vigilance, adaptability, and informed decision-making remain paramount. Understanding the nuances of this early-year update and recognizing the broader trends enable stakeholders to navigate the evolving 340B landscape effectively, ensuring compliance and maintaining program integrity amidst a potentially challenging year ahead.

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