NCPA submits comments on draft MTF 835 companion guide

NCPA June 2, 2025

NCPA submitted comments to CMS on the draft Medicare Transaction Facilitator (MTF) 835 Companion Guide. The draft guide addresses how electronic remittance advice (also "835 eRA") is created and transmitted from the MTF to pharmacies and other dispensers for refunds owned to the pharmacy from a drug manufacturer for dispensing a prescription eligible for the Maximum Fair Price negotiated in the Medicare Drug Price Negotiation Program. NCPA's comments focused on the need for details on testing transmitting 835 eRAs between the MTF and the pharmacy or pharmacy's third-party support entity and the situation where an error occurs when a Part D plan submits prescription drug event data resulting in a delay of the refund payment owed to the pharmacy.

CMS has a dedicated page for pharmacies who want more information. NCPA has raised on numerous occasions pharmacy owners' concerns with this program, including these MDPN program talking points.

NCPA