Independent Insights, a Health Mart Podcast

Episode 18: MTF Enrollment: What Pharmacies Need to Know Before November 15

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Under the Inflation Reduction Act (IRA), government-negotiated drug prices for high Medicare spend drugs will take effect on January 1, 2026. Pharmacies must enroll with the CMS Medicare Transaction Facilitator (MTF) to receive manufacturer refunds when the acquisition cost exceeds the Maximum Fair Price (MFP). Without enrollment, they may be excluded from the program.

In this episode, we break down the critical steps pharmacies must take to enroll in the CMS MTF ahead of January 1, 2026. With manufacturer refunds hinging on proper enrollment, we explore the six-part form, key financial selections, and the role of third-party entities. We also spotlight the urgency of completing the enrollment by November 15, 2025, to avoid delays in reimbursement, for those wishing to participate in MTF. 

Host
Suzanne Feeney, PharmD
VP, Pharmacy Retail Operations
McKesson / Health Mart

Guests
Emily Flaugher
Vice President and General Manager of Payer Solutions
McKesson / Health Mart Atlas

Resources
Pharmacy Toolkit on Medicare Transaction Facilitator Available
CMS has released a pharmacy toolkit on the Medicare Transaction Facilitator (MTF) as part of the Medicare Drug Price Negotiation Program (MDPNP). The toolkit provides important information and step-by-step instructions for enrolling your pharmacy in the MTF Data Module. Additional pharmacy and dispensing entity resources are available here. As a reminder, implementation of the MDPNP will begin on January 1, 2026; pharmacies will still be able to enroll after this date.

References
Helpful CMS.gov Resources: 


The views and opinions expressed in this podcast are those of the guest and do not necessarily represent the views or positions of Health Mart, McKesson or its affiliates or subsidiaries ("McKesson”). The information provided herein is for informational purposes only and does not constitute the rendering of clinical, legal or other professional advice by McKesson.

Suzanne: [00:00:00] Welcome to Independent Insights, where we break down the most important updates shaping independent pharmacy today. My name is Suzanne Feeney, and I'm a pharmacist and the senior Director of Pharmacy Solutions on the McKesson Health Mart team. In this episode, we're diving into the CMS Medicare Transaction Facilitator or MTF, and why timely enrollment is critical for pharmacies ahead of the January, 2026 rollout of government negotiated drug prices. We'll be spotlighting the importance of completing the enrollment by November 15th, 2025 to avoid delays in reimbursement. So whether you manage one pharmacy or many pharmacies, we'll walk you through what you need to know, what to avoid, and how to make sure your pharmacy is positioned to receive manufacturer refunds without delay. So let's dig in.

Are you looking for ideas to grow independent pharmacy and make a greater impact in your community? Look no further. Welcome to Independent Insights, the podcast brought to you by Health Mart. Episodes delve [00:01:00] into a wide range of topics to provide you with the practical strategies, expert insights, and inspiring stories to help you and your pharmacy excel.

The information provided is intended for informational purposes only and does not constitute clinical, legal, or any other type of professional advice from Health Mart, McKesson, or its affiliates and subsidiaries (“McKesson”). You acknowledge and agree that McKesson will have no liability with respect to, or relating to any information presented in this podcast. Pharmacies are encouraged to consult with their legal and business advisors before making any decisions that could affect their business operations.

Pharmacists are expected to exercise reasonable care as dictated by legal and professional standards and are ultimately responsible for decisions related to [00:02:00] patient care and medication management. It is your responsibility to review and comply with all applicable state and federal laws, rules, and regulations governing your business operations. This includes laws applicable to businesses in general, those pertinent to employers, and those specifically regulating the practice of pharmacy.​

Suzanne: With us today, we have Emily Flaugher, and Emily is the Vice President and General Manager of Payer Solutions at McKesson Health Mart Atlas.

That was a little mouthful there, Emily. Welcome. We're glad to have you today. 

Emily: Thank you so much for having me. I appreciate it. 

Suzanne: Yeah. Well, we're definitely here to talk about the deadline, but before we get to that and really spotlight the importance to get everyone to apply, help us understand a little bit about what MTF or Medicare transaction facilitator enrollment really is and why it matters to pharmacies right now.

The midst of flu season, this episode is gonna go out in October. People are busy. Why do we want them to pay attention right [00:03:00] now, and not miss this? 

Emily: Yeah, absolutely. Well, I think in order to really understand, and I'm gonna take us back a little bit and speak more about IRA or the Inflation Reduction Act, which was signed into law in 2022. According to that particular law, there was a lot of different elements that were gonna be implemented over time, and so we saw early on in the implementation, various things that impacted manufacturers around their pricing. This past year in 2025, we saw a lot of changes come from IRA that impacted the patient benefit design. So for example, the $2,000 out-of-pocket max for patients on Medicare. We also saw the introduction of the Medicare prescription payment plan or M3P also known as copay smoothing. So this ability for patients to not pay their copay at the counter, but really spread it over months and pay via an invoicing process with their plan sponsor. And so you've had a lot of elements to [00:04:00] IRA being implemented over time. For 2026, we're seeing yet another element of IRA being implemented, and that's around maximum fair price or MFP. So essentially, CMS has identified high dollar spend drugs under the Medicare benefit that is introducing a lot of cost to plan sponsors, to CMS, to government. So they're trying to find ways to mitigate that. For 2026, there will be 10 drugs that have been identified. And where CMS has negotiated a price directly with the manufacturer, that would be essentially the listed MFP. Now, with that, while that is a reduced price, there's a lot of components that are going to impact pharmacies on how cash flow happens on how processing and responses back from PBMs happen, so that's where we're introducing and talking the complexities of this MTF enrollment and really what it [00:05:00] means to pharmacies. So part of the introduction of some of these new processes introduces this new Medicare transaction facilitator to help piece some of those components together.

I'll maybe pause there, Suzanne, just to see if that helps give a little background and we can certainly dig in more to the semantics of how it works. 

Suzanne: Yeah, that is certainly helpful. And I like the perspective of all the changes that have come with IRA 'cause I do remember the M3P and that launched and there were some procedural changes in pharmacies and awareness of that and then this next step is really related to how the drug would be reimbursed. And I think you talked about that, where there's monies coming in from the traditional sense, but also that manufacturer component, which is a new layer for pharmacies. And if we haven't been paying attention, we've been really focused on our business or other things that could sneak up and then you're missing a piece of that reimbursement pie come 2026.

Emily: Yeah, absolutely. Let me maybe dig into a little bit more of the components of that. When you're [00:06:00] traditionally reimbursed for any Medicare script that you process whether you're doing contracting on your own, leveraging another entity like a PSAO to do contracting for you, you have your brand medications, which is really what CMS has identified in this process, those 10 products I mentioned are all brand medications. And traditionally in a Medicare contract, A PBM will reimburse you AWP minus X percent. That's generally the structure of how reimbursement is modeled. And that reimbursement will come in the form of both the patient copay and or what the plan sponsor then owes you that the PBM facilitates and that all gets wrapped up into a neat 14 day window, right? So you adjudicate the claim, you collect the patient copay, and then within 14 days after that, you're also getting the PBM portion of that reimbursement. For MFP again, the idea is to reduce overall spend, this maximum fair price or MFP is a very much reduced rate as [00:07:00] compared to what you would typically see in an AWP minus contract. So 50 to 60% reduced of what you would typically see. So how it's going to work is that contractually, PBMs or plan sponsors can pay you up to MFP, so they cannot pay you any higher than MFP. So within that patient copay and that 14 day window that you typically see PBM reimbursement, you'll be paid for that claim at that listed MFP price.

Now, part of this program, CMS, is requiring manufacturers to make pharmacies whole to what they've defined as acquisition cost. That's the part that's gonna be a little bit to be determined. We're waiting on some information to get published by CMS, but the running theory is that manufacturers will use WAC as the basis of acquisition costs to refund pharmacies.

So you'll get, once again, between the patient copay and the PBM within 14 days, you'll get [00:08:00] the MFP price, and then within an additional timeframe you should, as a pharmacy, get the difference between, again, the operating theory is WAC minus MFP from the manufacturer, and that's where this MTF or the Medicare transaction facilitator comes into play.

So each plan sponsor is required to submit to CMS and the MTF, these IRA scripts in the PDE file within seven days. And then that's starts the running clock for the manufacturer to refund you an additional 14 days on top of that. So we're really looking at potentially an extra seven days for you to get the full reimbursement picture for these 10 products. Any script you process for these 10 products.

Suzanne: That was a really great explanation, and I'm thinking it's like copay PBM reimbursement, 14 days, and then that extra seven days is the manufacturer piece of it. So it extends the timeline of payment by about a month, and how are those funds [00:09:00] coming into the pharmacy then? Is there a new process the pharmacies need to think about for that, for collection of those manufacturer funds?

Emily: So that's really gets down to the core of the topic today, which is the MTF enrollment. So every manufacturer that's part of this identified IRA MFP Program will leverage the CMS MTF for the data processing. Each pharmacy then, if they want to get and guarantee the manufacturer refund, they need to also enroll with the MTF.

So really important pieces of that enrollment process is first and foremost there was a lot of feedback sessions from industry partners and pharmacy perspectives to CMS as they built out this new process. They will be leveraging NCPDP as a source of truth to try to prevent a little bit of duplication for pharmacies in terms of entering their information.

So it's really important that each pharmacy knows who is in the NCPDP file as their authorized [00:10:00] official, as that is who CMS will email out the enrollment instructions to, and those enrollments actually started happening mid to late June in waves. You may have seen enrollment notifications go to that authorized official email from the NCPDP file and you essentially generate an account to start the enrollment process.

And so hopefully to make the system a little bit easier, it will actually copy over a lot of your NCPDP information, that way you don't have to duplicate efforts during that enrollment process. 

You're listening to Independent Insights, a McKesson Health Mart podcast with host Suzanne Feeney, Senior Director Pharmacy Solutions at McKesson Health Mart. And guest, Emily Flaugher vice President and General Manager of Payer Solutions at McKesson Health Mart Atlas.

 Let's continue. 

Suzanne: Okay, so pharmacies have the choice to enroll. I can't really see any reason why you wouldn't want to enroll if you're dispensing these 10 drugs. It seems pretty [00:11:00] straightforward and what I heard from you is that it's these 10 drugs, there's an enrollment process that's already started that has to happen by 11/15 and really make sure that whoever the authorized official is within NCPDP is checking their emails for this process.

Emily: Yeah, that's exactly right. It's a rolling enrollment, right? We know pharmacies open up every day or there's change of ownership, so the enrollment process never actually closes. It's really just in order to get prepared for January one, CMS is recommending that pharmacies finish that enrollment process by November 15th. That way they can process everything on their end and really ensure that for those that want to get started processing these IRA drugs, come January one, you have the best chance of squeezing that cash flow time crunch of 21 days, no further than that to get your manufacturer refund because again, the bulk of your total reimbursement for these claims is actually gonna come from the manufacturer [00:12:00] refund portion. So doing the enrollment does not require you in any way to dispense these products, but if you do, you'll have that extra layer of protection to make sure that you're getting the majority of the reimbursement that you expect on these. 

Suzanne: Okay. I'm sure that's the question everyone listening has, is that this change is going to bring up some concerns regarding pharmacy cashflow. And I think your insights around what that looks like as far as the timeline and why it makes sense to pay attention to this now in October, are really helpful there. Any other considerations around pharmacy cash flow related to MTF? 

Emily: Yeah, so , that is really what we're anticipating and trying to get the message out is for pharmacies to be prepared because again working theory is that you're gonna be made whole to WAC at the end of the day. You're gonna have at least a seven day delay in receiving the bulk of your payment for these claims. Now, one thing that you can do during the enrollment process, if you're [00:13:00] using reconciliation vendors, for example, to help you with pharmacy reconciliation, like McKesson's ProviderPay they may be enrolling within the MTF as well because the MTF does allow third party support entities to enroll as an extra layer of service or solution for pharmacies. So in the example of ProviderPay, they will be enrolling in the MTF and you can actually select during enrollment that you would like the copies of the remittance statements to go to ProviderPay as an example. So if you're using another reconciliation vendor, just check in with them. If that's something that they would suggest that you do, is to mark that during the enrollment process, there's essentially two separate sections to the enrollment. A place where you say where you want the manufacturer payments to go, which we're recommending those payments to go directly to your pharmacy and then also where you would like the remittance statements to go.

And if you want remittance statements to go directly to you and or to a third [00:14:00] party support entity, like a reconciliation vendor. So that'll help a little bit with the cash flow. I would say if you're not leveraging a reconciliation vendor today, certainly signing up for one would be very helpful. It obviously won't speed up payment in any manner to this process, but the visibility is gonna be really important because I think the other aspect to remember which is a little different, for example, than the M3P process that started is it is not gonna operate like a coordination of benefits claims. So you're not gonna process these claims to a PBM and then also process them to the manufacturer, right? It's still just a singular transaction, but within that adjudicated response, and we've seen PBMs communicate, they'll use the approved messaging field on the adjudicated response. They will identify that it's an IRA claim, that you should expect a manufacturer refund to come and manufacturers are gonna be using standard 835 files, but you'll essentially have two separate 835 files, two separate payments, all [00:15:00] tying back to a single Rx. 

Suzanne: Okay. And then processing what you're saying, if you, if our listeners out there don't have a reconciliation vendor, then it is critically important that they're manually looking at what's coming in in that post seven days, because that's gonna be the larger chunk of the reimbursement for the prescription, and reconciling that manually. So for those that don't have one, there is still time to look at services out there, prior to filling out the form, because I heard you mention Emily, that there's two parts to it. There's where you want payments to go, where you want remittance to go, so getting signed up for a third party support so you're not manually reconciling and missing those large chunks and then putting that on the application, that sounds like the right flow as far as logistics. 

Emily: Absolutely and keep in mind it's not a easy couple day turnaround to get a reconciliation vendor up and running. The core chunk of those processes will take at least 30 days. Every PBM has a different [00:16:00] process for enrolling and getting payment started and through a reconciliation vendor. So you really wanna give yourself a good 60 to 90 days even to get comfortable with setting up a reconciliation vendor. So the sooner you can get on that, if you're not already leveraging one certainly the better.

Suzanne: Okay. And can we make adjustments to forms later? So if someone's listening in October and doesn't have a vendor, they submit, they don't wanna wait to submit the MTF form, can they go back and do an addendum if they do work with a third party reconciliation service later for those remittance statements through CMS.

Emily: Absolutely. That is our understanding. So this enrollment is essentially gonna be open-ended, and my understanding is when you get that process started, you're essentially creating a portal account. So you should be able to log in at any time and make adjustments as changes happen within your business and CMS has put out a lot of great resources.

We're certainly not here to reinvent the wheel by any means, and I would [00:17:00] recommend that you lean on those CMS resources. They have a page dedicated to dispensing entities. They have a page dedicated to the product listing, so all of the NDCs associated with the IRA drugs that have been identified and what those published MFP price points are. And then they also have FAQ and enrollment guides where they'll actually do screenshots of their enrollment system and what each section entails. 

Suzanne: That's great, and we can put some of the links to those references that you just made from CMS in the show notes. So for those of you who are listening in, those will be available in the show notes. Awesome. Okay, Emily, that's a lot of great information. I feel like it was easy to digest. We went through all the stages. Anything that we're missing that you wanna make sure the listeners hear? 

Emily: I think we covered a lot of it. My, biggest takeaway for all customers is just be as prepared as you can be. So you have ways and resources available to you to know which of these products are impacted, there's ways [00:18:00] to identify within your system which claims are associated with Med-D versus not, because again, this process just impacts Medicare. And then just be as safe as you can be and prepared as you can be by enrolling in that MTF as early as possible. That way if you are dispensing these products for Medicare patients, you can make sure not to miss out on that manufacturer refund portion. 

Suzanne: That makes a lot of sense. So I think we've said it enough but it's not necessarily a deadline, the goal is to have pharmacies enrolled by November 15th so that you're not missing out on those critical manufacturer funds in that additional week for coming whole on the reimbursement side.

So I would just, reiterate that to everybody listening and while enrollments do remain open, like you said, Emily's submissions can be edited after the date. So really take action now. Review your selections carefully. 

Check out the links we'll put in the show notes and if you are interested, reach out to Health Mart Atlas customer support for information on ProviderPay or questions around this.

Thanks for joining us on [00:19:00] this episode of Independent Insights. We broke down the critical steps pharmacies should take if they plan to participate in the CMS Medicare Transaction facilitator or MTF enrollment ahead of the January 2026 rollout of government negotiated drug prices. As Emily Flaugher, vice President and General Manager of Payer Solutions at McKesson Health Mart Atlas highlighted, timely enrollment by November 15th is key to ensuring your pharmacy receives manufacturer refunds without delay. Especially for those dispensing the 10 identified IRA drugs.

We cover the impact of the inflation reduction act, new reimbursement timelines, and practical tips for managing cash flow, including the importance of reconciliation support, and keeping your NCPDP information up to date.

Remember, while enrollment remains open, acting now will help you avoid delays and keep your business running smoothly. Check out the show notes [00:20:00] for helpful links to resources. Stay proactive, stay informed, and thanks for listening to Independent Insights. We'll see you next time.

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