Medicare’s Maximum Fair Price (MFP) officially went live on January 1st. Select Medicare Part D drugs are now subject to negotiated pricing under the Inflation Reduction Act, with 15 additional Part D drugs set to come online in 2027 and beyond.
For pharmacy leaders going live this month, it’s still early days and some health systems just received their initial refunds on January 21st. We are hearing a growing number of questions from our covered entity (CE) customers around how MFP reconciliation efforts will actually work in practice, and where the risks are hiding.
One thing is already clear: MFP will not be a simple pricing adjustment. It introduces new reconciliation workflow, new cash-flow dynamics, and complexity that pharmacy teams will need to actively manage. Many organizations are just beginning to define their strategy, and the early signals are worth paying attention to now, before volume and complexity scale.
Read on for a summary of what we know about MFP today, what we’re hearing from Plenful customers reviewing their initial refunds, and how we’re planning to support CEs through purpose-built workflow automation.
MFP is live, but reconciliation strategies are still forming
MFP applies to a limited set of Part D drugs, but its footprint will expand quickly. That matters because the program’s design places a meaningful share of the operational complexity downstream.
Under MFP, pharmacies dispense and adjudicate Part D prescription claims as they do today. Reimbursement from Part D plan sponsors for the select MFP drugs is now limited to the Maximum Fair Price (MFP) plus a dispensing fee. Plans submit prescription claim information to CMS’s Drug Data Processing System (DDPS), which then passes specific data elements along to the Medicare Transaction Facilitator (MTF) Data Module (DM). Manufacturers utilize the claims data from the MTF DM to determine which claims are eligible for an MFP refund and the appropriate amount, a process called “Effectuation”. Manufacturers have 14 days to effectuate the refund and return the corresponding data to the MTF DM. Given the various stakeholders and different steps, pharmacies could see their refund up to 26 days after the prescription claim is adjudicated.
As a result, many covered entities are building financial oversight and a reconciliation process. Here’s what the complexity of the MFP transition can mean for covered entities, and challenges to consider:
Challenge 1: Missing MFP refunds
The first challenge is to ensure your pharmacies are not missing MFP refunds. The 340B Rebate Model was poised to serve as the source of truth for 340B-eligible claims, but with that program on pause, a fully operational Part D 340B repository does not exist. This means manufacturers must rely on limited and imperfect signals such as modifiers, self-identification, or evidence of purchasing patterns to inform eligibility.
Manufacturers have already publicly flagged (see pg. 5) this limitation: they do not have complete visibility into 340B eligibility based on available data shared from covered entities. Only covered entities possess definitive 340B determination data.
Consequently, during the effectuation process, if a manufacturer mistakenly assumes a claim is 340B—and the 340B price is lower than the MFP price—no MFP refund will be issued.
Challenge 2: MFP–340B duplication creates structural complexity
Identifying and resolving duplication between MFP and 340B pricing is another challenge. When both programs apply to the same claim, the lower price will always prevail.
In practice, if a 340B claim receives an MFP refund, de-duplication occurs on the MFP side. If MFP is below the 340B price, the pharmacy will still receive an MFP refund; however, it will be less than normal because the refund will be calculated as MFP minus 340B acquisition price. If the 340B price is below the MFP, the MFP would be credited to the pharmacy to be utilized on a future MFP-eligible claim.
This de-duplication process creates real financial complexity. Because credits are applied to future claims, the financial trail becomes harder to follow over time.
Challenge 3: Duplication credits are difficult to track manually
The third challenge is the crediting model itself.
Tracking these credits across pharmacies, claims, and manufacturers is manageable in theory, but extremely difficult in practice without the right tools.
For pharmacy teams already stretched thin, manually reconciling credits requires maintaining detailed claim history and understanding when and how credits are applied. If an error occurs, the burden falls on the pharmacy to identify the issue and initiate a correction. Manufacturers will accept feedback and attempt to address corrections via processes like Good Faith Inquiry Forms (see pg. 6) for dispute resolution, but this requires time, effort, and oversight from already lean teams.
As more drugs are added to MFP, this will become increasingly complex. Without clear visibility, it becomes harder to answer a basic question finance teams care deeply about: Were we actually made whole?
Challenge 4: Reconciliation volume creates a capacity problem
Unlike the proposed 340B Rebate Program Pilot, MFP is not a data submission problem. Pharmacies are not submitting claim files. Instead, the complexity shows up after the fact, during reconciliation.
Each MFP-eligible Part D claim must be reviewed to confirm:
- Whether MFP was applied during drug acquisition or retrospectively via refund
- Whether the expected refund was received
- Whether any credits were issued or applied
- Whether the purchase acquisition price changed the refund calculation
For pharmacies with meaningful Part D volume in MFP-selected drugs, this quickly becomes a claim-by-claim exercise. That creates a capacity issue, not just an administrative one. Teams must invest time and attention simply to build confidence in their revenue timing and cash flow — work that grows as the program expands.
Why automation will matter more as MFP scales
As MFP expands to more drugs and thus more claim volume, it will become increasingly difficult for pharmacies to manage reconciliation through manual workflows alone. The combination of retrospective refunds, ledger-based credits, and 340B de-duplication creates a new level of operational complexity that simply wasn’t present before.
At Plenful, we’re building capabilities specifically to support covered entities participating in MFP, drawing on the same principles that have guided our work in 340B Rebate Management. As a designated Third Party Support Entity (TPSE), Plenful is focused on reducing the administrative burden pharmacies face by:
- Automating reconciliation and visibility around new MFP refunds to reduce the administrative burden on pharmacies. Plenful’s workflow automation platform will:
- Access MTF data and remittance information on behalf of pharmacies through the MTF as a Third Party Support Entity (TPSE)
- Reconcile expected vs. received MFP refunds at the claim level
- Identify duplications or credits in scenarios where both MFP and 340B apply
- Provide clear, claim-level visibility and reporting within Executive 360 Dashboards so pharmacy leaders can confidently manage revenue timing and cash flow, and feel prepared to report key learnings
The goal is not just efficiency, but giving pharmacy teams a confident and reliable way to understand where money is owed, where it has been paid, and where follow-up is required.
As MFP moves from 15 drugs to a permanent fixture, these capabilities will matter less as “nice to have” tools and more as core operational support.
Watch this space
MFP is still new. Guidance continues to evolve, manufacturers are refining their processes, and pharmacies are closely monitoring and learning from live data.
Pharmacy leaders who start paying attention now will be better positioned as the program expands. Understanding where refunds can go missing, manufacturer credit utilization, and where reconciliation breaks down is the first step toward building durable operations under MFP.
At Plenful, we’re partnering closely with health system customers as these dynamics unfold, using real-world learnings and best practices to inform how reconciliation, visibility, and automation should evolve.
We’d love to stay in touch: you can find me here on LinkedIn and explore Plenful’s 340B solutions online.
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