NASP Submitted Comments: Response on MTF Agreements Feedback
The National Association of Specialty Pharmacy (NASP) writes in response to the request for pharmacy stakeholder feedback on the draft Medicare Drug Negotiation Program Medicare Transaction Facilitator (MTF) contract agreements released for comment in December 2024 as proposed under the Biden Administration. NASP urges the Trump Administration to pause any finalization of these MTF agreements and to instead work with the pharmacy/dispensing community to immediately revisit and revise the operational plan for pharmacies/dispensing entities and manufacturers to engage with the new Medicare Transaction Facilitator (MTF) under the Inflation Reduction Act’s (IRA) Medicare Drug Negotiation Program. The approach proposed under the Biden Administration to implement in 2026 maximum fair prices (MFPs) and reconcile payments to the pharmacies that dispense the negotiated drugs threatens specialty pharmacies and other pharmacy businesses across the United States. NASP does not believe that the process outlined by CMS accurately interprets the IRA statute and remains extremely concerned the approach proposed will work against any effort to implement the Medicare Drug Negotiation Program. While we are grateful for the CMS career staff’s efforts to engage with the pharmacy community, it is paramount that the Trump Administration immediately intervene and work with the pharmacy/dispensing community to reconsider and revise this process.