Maximum Fair Price (MFP)

Maximum Fair Price (MFP)



Registration Links

Medicare Transaction Facilitator (MTF): https://mtf.cms.gov/mtfdm/login

Beacon MFP (Optional): Beacon


340B Beacon Rebate Model:

https://cm.beaconchannelmanagement.com/



BestRx_2025_2 - Copy.png

 


Maximum Fair Price

The Maximum Fair Price (MFP) is a CMS-negotiated price for select high-cost Medicare Part D drugs under the Inflation Reduction Act, effective January 1, 2026.

MFP sets the maximum amount Medicare Part D and Medicare Advantage plans will reimburse at the pharmacy level.

For 2026, 10 drugs (300+ NDCs) are included, with additional products added annually and expansion to Medicare Part B in 2028.

Manufacturers must provide MFP pricing for eligible Medicare Part D beneficiaries.

https://www.cms.gov/files/document/fact-sheet-negotiated-prices-initial-price-applicability-year-2026.pdf

Screenshot 2025-12-22 103041.png

What does this mean for pharmacies?

  • PBMs may reimburse pharmacies no more than MFP plus the dispensing fee.

  • Manufacturers must refund pharmacies the difference between MFP and actual acquisition cost.

  • CMS recommends a Standard Default Refund Amount (SDRA) of WAC minus MFP, though manufacturers can choose a different method.

  • Refunds are due within 14 days after manufacturers receive plan data; delays may result in 21+ days before pharmacies receive payment.

  • Current WAC: ~$606 for a 30-day supply

  • CMS-negotiated MFP (2026): $231 for a 30-day supply

  • Pharmacy submits claim to the Medicare Part D plan

  • Plan reimburses: $231 (MFP) + dispensing fee

  • PBM/processor returns estimated SDRA: $375 (WAC − MFP) on claim response

  • Manufacturer funds refund: $375 through the Manufacturer Transaction Facilitation (MTF) process within 14 days

  • Net to pharmacy: $231 (plan) + $375 (manufacturer) = $606, covering acquisition cost

Note: WAC is used as a surrogate for pharmacy acquisition cost; pharmacies typically acquire product below WAC.


Medicare Transaction Facilitator

  • The Medicare Transaction Facilitator (MTF) is a web-based platform that supports MFP effectuation under the Medicare Drug Price Negotiation Program (MDPNP).

  • MTF facilitates interactions between pharmacies and manufacturers related to MFP refunds.

  • The platform includes two modules:

    • MTF DM: Data Module

    • MTF PM: Payment Module

  • MTF matches claim data to determine manufacturer refund obligations.

  • Provides recordkeeping for all participating entities.

  • Pharmacies can retrieve 835 remittance files through MTF.

  • Displays payment details (electronic or check) and allows pharmacies to self-identify cash-flow concerns.

  • Pharmacy enrollment is required, even if the pharmacy does not plan to dispense MFP-eligible drugs.

Registration Link: https://mtf.cms.gov/mtfdm/login

Screenshot 2025-12-22 115222.png

Pharmacies are initially reimbursed at the MFP plus the dispensing fee, with the manufacturer refund paid later through the MTF.

Screenshot 2025-12-22 104947.png
  • Approved Message Code (548-6F) = 061: Indicates the claim is eligible for the Medicare Drug Price Negotiation Program (MFP).

  • Note: Message Code 061 identifies eligibility only and does not guarantee reimbursement at MFP; therefore, 522-FM = 46 may not always be present.

  • Basis of Reimbursement Determination (522-FM) = 46: Indicates reimbursement at Maximum Fair Price (MFP).

  • Additional Message Information Qualifier (132-UH) = 38: Flags estimated MFP SDRA.

  • Additional Message Information (526-FQ): Displays the estimated Standard Default Refund Amount (SDRA).

  • Claims may be reimbursed at the lesser of MFP, U&C, or contract rate.


MFP Reconciliation

  • MFP refund payments and 835 remittance files are issued by the Medicare Transaction Facilitator (MTF).

  • Refunds are deposited into dedicated bank accounts.

  • Remittances itemize MFP refund payments and flag SDRA adjustments using CARC 307.

  • When adjustments occur, RARC codes explain the reason (e.g., 340B pricing, prospective MFP purchase).

  • Note: CARC 307 and RARC codes appear only when the payment is not equal to SDRA.

Screenshot 2025-12-22 120323.png

 


Beacon MFP

Beacon

Optional enrollment is free for pharmacies and provides additional benefits.

  • Beacon MFP is an IT platform used by manufacturers to validate MTF refund payments for all 2026 MFP drugs.

  • MTF participation is mandatory; Beacon MFP is an optional supplemental tool.

  • Beacon MFP benefits include: rebate processing status, financial visibility, good-faith inquiries, 340B de-duplication, exportable data, and support resources.


BestRx MFP Enhancements

BestRx should be updated to the latest version if enhancements do not appear.

If still having issues Support should update BestRx and ERX to latest version

MFP in Drug File

Negotiated drugs under the Inflation Reduction Act (IRA) will display the MFP Price in the Drug File.

MFPDrugFileProd-20251119-153018.jpg

MFP in Drug Listing

An MFP filter has been added to the Drug Listing report that will display only MFP qualified drugs.

MFPDrugListingProd-20251119-152654.jpg

MFP in Claim Response

The Claim Response screen will display the MFP SDRA (Standard Default Refund Amount), and the Estimated Gross Profit After MFP SDRA.

These values are only displayed when they are received in the claim response for Rx’s containing MFP drugs.

BestRx is currently working on 835 processing to reconcile MFP claims and remittance advice downloaded from the MTF.

MFPClaimRespScreenProd-20251121-173014.png

HRSA 340B Rebate Model Pilot Program

  • Allows 340B pricing to be effectuated as a rebate for drugs also subject to the MFP program.

  • Covered entities purchase at WAC and receive a rebate to reduce the net cost to the 340B ceiling price.

  • The rebate is calculated as WAC minus ceiling price.

  • The goal is to increase manufacturer transparency and prevent duplicate discounts.

Beacon Rebate Model

  • A separate IT platform from Beacon MFP used to effectuate the 340B Rebate Model Program.

  • Applies to 340B covered entities only.

  • Covered entities must submit pharmacy data directly or via a Third Party Administrator within 45 days.

  • Beacon pays the rebate directly to the covered entity.

  • Failure to register prevents access to 340B rebate payments for products included in the HRSA 340B Rebate Model Pilot.
    Registration Link: https://cm.beaconchannelmanagement.com/


Additional Questions

Does this change pharmacy staff workflow or add steps?

No. There is no change to staff workflow at the time of dispensing or claim submission.

Does RedSail send data to the MTF?

No. Pharmacy management systems do not send data directly to MTF.

PBMs/processors transmit claim data to CMS/MTF.

How does IRA MFP work with 340B?

Manufacturers are not required to pay duplicate discounts.

Manufacturers must extend the lower of 340B or MFP pricing.

How are 340B claims handled and are duplicate discounts prevented?

Manufacturers are responsible for preventing duplicate discounts.

If a claim is flagged as 340B (via SCC), MTF passes that information to the manufacturer.

This is why manufacturers use Beacon MFP and the Beacon 340B Rebate Model.

How can Medicaid still be billed at 340B cost if wholesalers don’t publish ceiling prices?

Covered entities may need to manually enter ceiling prices from the Beacon 340B Rebate platform.

Ceiling price files are only available to 340B covered entities and not to compendia.

HRSA recommends working with state Medicaid agencies to establish billing best practices.

Will the claim look like a loss, or can the manufacturer refund be seen?

The estimated SDRA (refund amount) is visible on the claim response.

Additional transparency is available through product-specific MFP webinars and documentation.


 

© BestRx Pharmacy Software