The Centers for Medicare & Medicaid Services (CMS) updated its FAQ clarifying that pharmacies do not need to actually dispense drugs under the Medicare Drug Price Negotiation Program (MDPNP). Specifically, CMS stated that “Enrolling in and using the MTF DM is free for pharmacies and the act of enrolling itself does not place any requirement on pharmacies to engage in the Part D program or to dispense any drugs under the Medicare Part D program; that is, pharmacies that enroll in the MTF DM retain the ability to make future decisions related to their Part D participation.” This follows an earlier letter that CMS Administrator Mehmet Oz sent to Rep. Buddy Carter (R-Ga.) making the same clarification.
Additionally, CMS' Medicare Part D final rule from April 2025 says PBMs must put contractual language in place obligating pharmacies to participate in the MDPNP if they participate in any Part D network. Based on the letter from Oz, it appears that the rule requires pharmacies to enroll in the MTF but does not require them to actually dispense drugs covered by the MDPNP.
Here is the regulatory requirement:
"§ 423.505 Contract provisions. * * * * * (q) Enrollment in the Medicare Transaction Facilitator Data Module for the Medicare Drug Price Negotiation Program. For contract year 2026 and all subsequent years, any contract between the sponsor and a pharmacy, or between a first tier, downstream, or related entity and a pharmacy on the sponsor's behalf, for participation in one or more of the Part D sponsor's networks must include a provision requiring the pharmacy to be enrolled in the Medicare Transaction Facilitator Data Module (MTF DM) (or any successor to the MTF DM) in a form and manner determined by CMS. Such provision must also require the pharmacy to maintain and certify up-to-date, complete, and accurate enrollment information with the MTF DM, in accordance with applicable terms and conditions of participation with the MTF DM, including but not limited to contact, third-party support entity or entities, and banking information, in a form and manner determined by CMS."
While CMS may not require pharmacies to dispense MFP drugs, PBM network agreements might, so read your contracts carefully.
NCPA will keep its members posted on any developments. For resources on the MDPNP, click here.
