HB 4878 Advances - But 340B Transparency Questions Remain Unresolved
Michigan House Bill 4878 cleared the House Health Policy Committee this week, advancing with a committee substitute (H-3) and moving next to the House Rules Committee. While the bill’s sponsors have characterized the substitute as a “transparency” compromise related to the federal 340B drug pricing program, the revised language does little to meaningfully illuminate how 340B hospital profits are actually generated, deployed, or aligned with the program’s original safety-net intent.
The substitute retains state-level reporting concepts aimed at hospitals participating in 340B, but notably stops short of requiring disclosure that would connect discounted drug acquisition costs to downstream patient benefit, charity care expansion, or reduced out-of-pocket costs. In practice, the revised reporting framework risks creating the appearance of oversight without delivering actionable insight into whether 340B margins are being used in ways consistent with the national program’s purpose.
From a biopharma and life sciences industry perspective, this distinction matters. Manufacturers are required - under federal law - to provide steep discounts through 340B, yet neither HB 4878 nor its substitute addresses the core structural issue: how those federally mandated discounts translate (or fail to translate) into patient affordability and access. Without standardized, outcomes-oriented reporting tied to patient impact, state-level transparency mandates risk becoming administrative exercises rather than policy solutions.
MichBio raised these concerns directly in a letter of testimony submitted for the House Health Policy Committee hearing, formally opposing HB 4878, emphasizing that the bill’s reporting framework would not provide meaningful insight into 340B program compliance or patient benefit, while potentially reinforcing a flawed policy narrative that overlooks the need for consistent, federally driven oversight.
This concern has been echoed in broader coverage of Michigan’s 340B debate, where manufacturers, providers, and policymakers continue to spar over whether incremental state action can fix what is fundamentally a federal program design and enforcement challenge. As Michigan Advance has reported, stakeholders on all sides acknowledge that the most consequential levers governing eligibility, compliance, and enforcement remain squarely under federal jurisdiction, not state statute.
HB 4878 now moves to the House Rules Committee, where leadership will determine whether - and when - the bill is scheduled for floor consideration. While Rules review is a procedural step, it represents a critical inflection point for stakeholders seeking either further amendment or a broader reframing of the issue.
For Michigan’s life sciences and biopharma community, the bill’s movement underscores a larger reality: piecemeal, state-level transparency requirements are unlikely to resolve longstanding 340B concerns. Meaningful reform - particularly around accountability, patient benefit, and consistent compliance standards - will ultimately require federal action, federal data, and federal enforcement mechanisms.
MichBio will continue to track HB 4878 as it advances and will remain engaged in discussions that support predictable policy, fair market dynamics, and patient-centered outcomes across the drug development and delivery ecosystem.
