Alan J. Arville and Spreeha Choudhury, attorneys in the Health Care & Life Sciences practice, in the firm’s Washington, DC, office, co-authored an article in Pharmacy Times, titled “Preparing for the Medicare Transaction Facilitator.”
Following is an excerpt:
In January 2026, the Centers for Medicare & Medicaid Services (CMS) will implement the first negotiated prices under the Inflation Reduction Act’s Medicare Drug Price Negotiation Program. Pharmacies that dispense drugs selected for negotiation must prepare now for the operational changes that will accompany these new requirements—most notably, the rollout of the Medicare Transaction Facilitator (MTF) system.
The MTF will serve as a centralized infrastructure to support the transmission of data and payment elements necessary to implement maximum fair prices (MFPs) for selected Medicare Part D drugs. Dispensing entities will be required to participate in the MTF to remain in network with Medicare Part D plan sponsors and ensure proper reimbursement.
