NASP Submitted Comments on Draft Medicare Transaction Facilitator (MTF) Agreements
CMS has requested public comment on draft Medicare Transaction Facilitator (MTF) agreements that outline the responsibilities of each party engaged with the Medicare Transaction Facilitator, a core component of implementing the Medicare Drug Price Negotiation Program. CMS anticipates finalizing these draft agreements for use by the MTF DM (data manager) for dispensing entity enrollment as soon as Spring 2025.
For more information about these agreements, please click here (PDF) to view the FAQs provided by CMS.
NASP has submitted comments to CMS based on feedback from our pharmacy and manufacturer members on these agreements:
“The National Association of Specialty Pharmacy (NASP) is pleased to provide feedback on CMS-4208-P, Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program and Medicare Prescription Drug Benefit Program. NASP’s comments focus on the proposed policy changes that would impact specialty pharmacies that participate in the Medicare Part D (Part D) and Medicare Advantage Prescription Drug (MA-PD) programs, the agency’s RFI request on Medical Loss Ratio reform, as well as policies associated with implementation of the Inflation Reduction Act Drug Pricing Reform efforts. Despite 2024 regulatory adjustments made by CMS to address post point of sale price concessions and pharmacy DIR abuses over so many years, business operations of non-affiliated1 specialty pharmacies have continued to be significantly harmed. Several specialty pharmacies have had to restructure their operations, including laying off numerous staff members and cutting back on higher-cost inventory. Some specialty pharmacies have been forced to stop stocking and dispensing drugs to treat certain conditions due to certain Part D sponsors and their business entities’ historical targeting of specific specialty drugs for costly price concessions, resulting in significantly underwater and unsustainable reimbursement levels for specialty pharmacies…”