Certain individuals for dispensing entities listed under the National Council of Prescription Drug Programs data Pharmacy Database (“NCPDP Pharmacy Database”) likely recently received the CMS notice provided below regarding the Medicare Transaction Facilitator (“MTF”). This important notice is for the implementation of the Medicare Drug Price Negotiation Program (the Program) beginning on January 1, 2026. Importantly, the notice contains both immediate and future actions that are required by dispensing organizations in order to participate in the Program.
The Program required the Secretary of Health and Human Services (HHS) to negotiate prices with drug companies for certain drugs covered under Medicare Part D. On January 1, 2026, the negotiated maximum fair prices (MFPs), for the first ten drugs selected for negotiation go into effect.
Before the implementation of the Program, pharmacies and other dispensing entities will be required to enroll into the Medicare Transaction Facilitator (MTF). The MTF provides an avenue for dispensing entities to connect with manufacturers so the dispensing entity may receive refund payments when they pay more than the MFP to acquire a drug. As a note, it is currently unclear how the MTF will handle refunds in situations where a pharmacy purchases a drug at 340B pricing, but where an MFP has been negotiated for that drug. Advis will continue to monitor and provide updates on this one additional guidance has been presented.
In the near future, your dispensing entity’s primary point of contact (POC) as listed on your NCPDP enrollment record will need to:
- Verify their identity via CMS’ Identity Management (IDM) system;
- Create an account with the MTF; and
- Attest to their role in the organization for the MTF.
As noted, enrollment is expected to begin June 2025. Accordingly, please expect the POC will receive communications about enrolling in the MTF, including a communication when enrollment is open via email (similar to the email, below).
As for more immediate action, prior to MTF enrollment, dispensing organizations should ensure information in the NCPDP Pharmacy Database is up to date as this is what the MTF will rely upon to validate enrollment. Inaccurate information may risk delay in MTF enrollment.
Please reach out to your Advis consultant with any questions or if you need any other assistance when enrollment communications are received.
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Greetings, Your Action is Needed CMS plans to utilize the NCPDP Pharmacy Database to identify and validate initial dispensing entity users, or “first users,” for access to the MTF. These users will be responsible for verifying their identity via CMS’ Identity Management (IDM) system, creating an account with the MTF, and attesting to their role in their organization for the MTF. In addition, the first user will be responsible for inviting downstream users from their organization to register for access. Review the NCPDP Pharmacy Database for your organization as soon as possible (if needed) The information that is contained in the NCPDP Pharmacy Database for your organization at the time of enrollment is what the MTF will rely upon to both 1) identify and validate “first users,” and 2) pre-populate certain fields in the “Dispensing Entity Enrollment Questionnaire, if permitted by the dispensing entity. Please ensure this information is up-to-date prior to beginning the MTF enrollment process. If, while completing your MTF enrollment, you find that you need to update your NCPDP data, please note that it may take at least 2 weeks from the date of your update until the MTF can use your data to support MTF enrollment. Connecting to Third-Party Support Entities (TPSEs) If you work with a TPSE, they will also get an email from us about setting up an account, but you must also complete the Dispensing Entity Enrollment Questionnaire and list your TPSE in that questionnaire Frequently asked questions and other resources to provide information to dispensing entities about MTF and the MTF enrollment process are available on CMS’ Resources for Pharmacies and Dispensing Entities webpage. If you have any questions about the MTF or MTF enrollment process, please contact MFPMedicareTransactionFacilitator@cms.hhs.gov. If you have questions about how to update your NCPDP data in Access Online, the system NCPDP uses to help pharmacies maintain their data, contact pharmacyhelp@ncpdp.org. |
Centers for Medicare & Medicaid Services (CMS) has sent this update. To contact Centers for Medicare & Medicaid Services (CMS) go to our contact us page. |
Published June 12, 2025
