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TIP: Compare your 340B net cost to the Maximum Fair Price (MFP) before submitting a rebate.
With MFP rebates soon to be part of Medicare Part D, the new considerations between the expected 340B rebate and relying on MFP can feel overwhelming. The easiest way to stay on top of it is to keep the process simple: compare your net 340B cost—including drug acquisition, TPA, and pharmacy fees—to the MFP. If 340B delivers the lower cost, submit the rebate. If not, let the MFP adjustment apply and avoid duplicate submissions.
340B covered entities should be aware that 340B prices are largely lower for the initial 10 MFP drugs. 340B, therefore, still presents significant purchasing benefits on these initial 10 drugs and should not simply be excluded. Taking this step not only reduces denials and streamlines reconciliation, it also helps protect your margin. Just as important, it creates a clear audit trail to support manufacturer reviews and potential appeals.
By building a quick cost check into your routine, you can minimize administrative burden while keeping your 340B program working to its full advantage.

Diana Sierra is Vice President, Contract Pharmacy Partnership at The Craneware Group. She can be reached at dsierra@craneware.com
