The MTF’s main function will be to ensure that pharmacies and other dispensing entities obtain access to MFPs negotiated reimbursement under the MDPNP, a process that CMS refers to as “MFP effectuation.”

As of June 2025, drug-dispensing entities and drug manufacturers can enroll in the Centers for Medicare and Medicaid Services’ (CMS) Medicare Transaction Facilitator (MTF) modules. MTF is an online portal established to implement maximum fair prices (MFPs) negotiated by CMS with drug manufacturers under the Medicare Drug Price Negotiation Program (MDPNP).

Pharmacies and other dispensing entities must enroll in the provider-facing part of the MTF (the data module) to receive refund payments for drugs whose prices were negotiated through the MDPNP. Enrollment is also necessary to participate in any Medicare Part D network in 2026.

Key action items for pharmacies, described in more detail below, include updating the pharmacy’s National Council for Prescription Drug Programs (NCPDP) database profile; having legal counsel review all affected contracts including the data module enrollment agreement and any new Part D plan contracts; and enrolling in the data module as soon as practicable, ideally by November 15, 2025. Pharmacies should ensure that their enrollment process is complete and correct while fully understanding the legal functions of the MTF data module to ensure they take full advantage of upcoming MFPs and do not experience any unanticipated changes in their participation in the Medicare Part D program.

As covered in previous Alerts from March 29 and October 13, 2023, the MDPNP was established by the Inflation Reduction Act and requires CMS to negotiate lower prices for several high-expenditure, single-source drugs and biologics every year, which result in the MFPs. The negotiated MFPs for the first round of negotiations (covering 10 Part D drugs) go into effect January 1, 2026—meaning that drug manufacturers may no longer charge more than the MFPs for those drugs and must issue refunds to certain dispensing entities that acquired the drugs at higher prices.

The MTF’s main function will be to ensure that pharmacies and other dispensing entities obtain access to MFPs negotiated reimbursement under the MDPNP, a process that CMS refers to as “MFP effectuation.” Drug manufacturers can provide access to MFPs both prospectively by selling a drug at its MFP and retrospectively by refunding entities that acquire a drug at a cost greater than the MFP. For refunds, manufacturers can issue these either directly through the MTF by enrolling in the manufacturer-facing part of the MTF (the payment module) or through another means of their choosing. Manufacturers opting to use another means had to detail the same in the MFP Effectuation Plan that they provided to CMS by September 1, 2025. CMS will publish these plans on the data module in fall 2025.

Enrolling in the data module is necessary to receive refunds for negotiated MFPs. Enrolling will also be necessary to participate in any Part D plan—a recent CMS final rule directs Part D plan sponsors to add a clause in their network contracts requiring dispensing entities to enroll. Finally, chain pharmacies should note that they need only complete a single, centralized enrollment covering all locations.

Action Items for Pharmacies

• Before enrolling, update the pharmacy’s NCPDP profile. CMS is using NCPDP information to auto-populate pharmacies’ enrollment applications, as well as to identify a “first user” for every pharmacy. The first user will be the contact person listed on a pharmacy’s NCPDP profile, typically the authorized signatory official or access manager. The first user will be responsible for enrolling the pharmacy in the data module and registering other pharmacy personnel to use the module, and CMS is emailing enrollment invitations to all identified first users.
• Before enrolling, determine which functions (e.g., central pay or reconciliation services) the pharmacy will assign to third-party support entities (e.g., pharmacy services administrative organizations or reconciliation vendors).
• Before enrolling, have the first user create an account with the CMS Identity Management system (unless they already have one).
• Before enrolling, determine whether the pharmacy has material cashflow concerns over dispensing MDPNP-negotiated drugs. Pharmacies with such concerns can indicate the same in the enrollment process, and manufacturers can provide assistance plans to such pharmacies.
• Once ready, have the first user enroll the pharmacy in the data module no later than November 15, 2025. There is no deadline for enrolling, but CMS recommends enrolling by this date to avoid delays when the first cycle of MFPs goes into effect in January 2026. If a first user has not received an email invitation from CMS, they can enroll by visiting the MTF website.
• While enrolling, consult CMS guidance for instructions. CMS has a series of guidance documents for data module enrollment, such as a dispensing entity enrollment questionnaire that lists the information collected during enrollment and a user guide with step-by-step instructions on how to enroll. CMS also has a dedicated help desk for providing technical support during enrollment.
• Before submitting an enrollment application, review the accompanying data module user agreement with legal counsel. Among other things, the agreement delineates roles and responsibilities for protecting the sensitive information housed and processed by the data module.
• Before signing a new Part D contract with a plan sponsor or pharmacy benefit manager, review it with legal counsel for any changes or requirements concerning the dispensing of MDPNP-negotiated drugs.
• At any time, determine who other than the first user should have access to the pharmacy’s data module account, according to the categories CMS established. Each account will be allowed to add up to three authorized signatory officials, up to three access managers and up to 10 staff end users, each of which have different levels of access to the account.

Given the significance of enrolling in the data module, pharmacies should ensure that their enrollment—along with all related tasks—is correct and complete, as well as ensure that they understand fully the legal functions of the data module and its role in both MFP access and Part D participation in general. Pharmacies that do so will be best situated to take full advantage of MFPs and to avoid any issues or unanticipated changes in their Part D participation.

For More Information

If you have any questions about this Alert, please contact Jonathan L. Swichar, Bradley A. Wasser, Taylor Hertzler, any of the attorneys in our Pharmacy Litigation Group, any of the attorneys in our Health Law Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.