Reminder to review your contracts on MDPNP

NCPA August 25, 2025

A friendly reminder that you should still closely review your contracts with PBMs and plans, and consult with your PSAO if applicable, to see if PBMs and plans are requiring you to dispense drugs under the Medicare Drug Price Negotiation Program. Any such requirement from PBMs and plans will govern, despite CMS stating that they will not require such dispensing in an updated FAQ and letter.

Centers for Medicare & Medicaid Services (CMS) staff delivered a webinar to over 600 members on enrollment in the Medicare Transaction Facilitator (MTF). The webinar can be found here.

You have probably received an email from CMS on enrolling in the MTF of the Medicare Drug Price Negotiation Program. If you are going to participate in any Medicare Part D network for next year, you must enroll in the Medicare Transaction Facilitator Data Module (MTF-DM ) to receive your manufacturer refund payments. We encourage you to become familiar with the process before enrolling. Here are some things to know:

  • You can watch an intro to the MTF on CMS' dispenser homepage here.

  • You can view a FAQ from CMS on the MTF here.

  • You can contact CMS at [email protected] with any questions.

  • Before enrollment, you should make sure your NCPDP profile is accurate and updated.

  • Before enrollment, pharmacies need to know which functions, such as central pay or reconciliation services, they want to assign to any third-party support entities such as PSAOs or reconciliation vendors.

  • During enrollment, pharmacies will need to sign a legal agreement so proceed with caution and be sure to carefully review and have your legal counsel review.

  • During enrollment, identify as having "material cashflow concerns," as manufacturers can provide pharmacies with a plan for mitigating their cashflow concerns.

  • For NCPA advocacy on the Medicare Drug Price Negotiation Program and the Inflation Reduction Act generally, see here.

There is no hard deadline to complete enrollment, and it will be available after January 2026. Enrollment will take approximately one hour and you will have to provide banking information.

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