Medicare Drug Price Negotiation: MTF Data Module Enrollment & Caremark Attestation

Starting in 2026, Medicare has negotiated the price of 10 brand drugs under the Medicare Drug Price Negotiation Program as part of the Inflation Reduction Act of 2022. The negotiations between CMS and drug manufacturers have resulted in Maximum Fair Prices (MFPs).

To implement this program, CMS has created the Medicare Transaction Facilitator (MTF) which will capture pharmacy dispensing data for respective Part D claims and send it to drug manufacturers via the “Data Module” (DM) and then return refund payments from manufacturers back to pharmacies via the “Payment Module” (PM).

Medicare Part D contracts require that network pharmacies enroll in this MTF. Failure to enroll will result in pharmacies losing out on manufacturer rebate dollars that will be necessary to cover the cost of the drugs. There will be a lag time between dispensing claims and receipt of refund payments, which is likely to create a cash flow problem for pharmacies – for this reason, CMS is encouraging manufacturers to expedite payments to pharmacies that self-identify (during enrollment) as having material cashflow concerns.

In addition to enrolling in the MTF DM, we have seen that PBMs also want assurances that pharmacies are completing this enrollment. Caremark sent a Pharmacy Update in October, requiring that pharmacies attest by December 31, 2025 on Caremark’s website confirming enrollment in the MTF DM. Caremark threatens a non-compliance fee for failing to attest.

The negotiated MFPs are not publicly available, however enrolled pharmacies should be able to see claims/refund data on the Beacon website which is managing the DM/PM.

PAAS Tips:

• Complete your Caremark Attestation by December 31, 2025
• Make sure your NCPDP profile information is accurate
• Enroll in MTF before 2026 to ensure you receive appropriate manufacturer refunds
• If you are concerned about cashflow concerns, make sure you identify as having “material cashflow concerns” during MTF enrollment
• See NCPA and CMS for additional resources

By Trenton Thiede, PharmD, MBA, President at PAAS National^®, expert third party audit assistance, FWA/HIPAA and USP 800 compliance.

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