Last week, NCPA joined with the American Society of Consultant Pharmacists to provide policy recommendations to manufacturers of the first 10 selected drugs covered under Medicare Part D to effectuate maximum fair price (MFP) for pharmacies with material cash flow concerns. NCPA and ASCP sent recommendations to the manufacturers as well as the trade associations PhRMA and BIO.
Among other things, NCPA and ASCP asked that manufacturers:
Pay the pharmacy the standard default refund amount (SDRA) as wholesale acquisition price (WAC) minus maximum fair price (MFP) for selected drugs;
Pay pharmacies within 14 days of the Part D plan adjudicating the claim;
Prefund MFP refund payments based on historic claims data from the pharmacy;
To allow for consistency in the process, effectuate the Standard Default Refund Amount (SDRA) payment via the Medicare Transaction Facilitator Payment Module (MTF-PM);
Work with pharmacies prior to the submission to CMS of manufacturers’ MFP effectuation plans, due Sept. 1, 2025, as pharmacies need to understand manufacturer payment terms to make decisions on PBM/plan contracts for 2026; and
In addition to any dispensing fees paid to pharmacies by the Part D plans, establish a reasonable “professional fee” and “administrative fee” for pharmacies dispensing selected drugs.
