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Medicare’s Maximum Fair Price (MFP) went into effect on January 1, introducing negotiated pricing for select Medicare Part D drugs under the Inflation Reduction Act (IRA). An additional 15 drugs are expected to follow in 2027 and beyond.
As a Third-Party Support Entity (TPSE), we’ve been working with large health systems that have adopted our MFP Intelligence solution, such as Henry Ford Health and St. Luke’s Health, to access Medicare Transaction Facilitator (MTF) remittance data as well as claims and 340B eligibility data through pharmacy management systems and third party administrators (TPAs). These partnerships have provided direct visibility into how MFP refund reconciliation is playing out in practice—and where gaps are emerging.
In many cases, those gaps are material. On average, up to 20% of expected MFP refunds are missing.
MFP is not just a pricing change. It introduces a new reconciliation workflow, new cash flow dynamics, and operational complexity that pharmacy and finance teams now need to manage.
As organizations move from initial implementation to ongoing management, three challenges are emerging:
Challenge 1: Missing MFP Refunds
The first challenge is to ensure your pharmacies are not missing MFP refunds. Manufacturers must rely on limited and imperfect signals, such as modifiers, self-identification, or evidence of purchasing patterns, to determine 340B eligibility.
Manufacturers have already publicly flagged (see pg. 5) this limitation: they do not have complete visibility into 340B eligibility based on available data shared from covered entities. Only covered entities possess definitive 340B determination data.
Consequently, during the effectuation process, if a manufacturer mistakenly assumes a claim is 340B—and the 340B price is lower than the MFP price—no MFP refund will be issued.
Challenge 2: MFP–340B Duplication Introduces Structural Complexity
Identifying and resolving duplication between MFP and 340B pricing is another challenge. When both programs apply to the same claim, the lower price will always prevail.
When a claim qualifies for both, de-duplication rules apply. But those rules introduce additional tracking requirements.
- If MFP is lower than the 340B acquisition cost, the refund is reduced (refund will be calculated as MFP minus 340B acquisition price)
- If the 340B price is below the MFP, the MFP would be credited to the pharmacy to be utilized on a future MFP-eligible claim
That means teams need to track not just whether a refund occurred, but how it was calculated and where that value is applied.
Most existing systems were not built to manage this type of cross-program reconciliation. As volume increases, it becomes harder to maintain a clear audit trail.
Challenge 3: Proper Reconciliation Can’t Scale Without Modern Tooling
MFP reconciliation requires data from multiple sources: pharmacy systems, TPAs, and MTF remittance files (835s).
Today, many teams are reconciling manually, pulling reports across disparate systems, organizing data manually in spreadsheets, and working backward to understand what happened at the claim level.
Two issues follow:
- Visibility is delayed when working reactively
- Manual work does not scale as volume increases
As more drugs enter the program in 2027 and beyond, the number of MFP-eligible claims will increase. This turns reconciliation into a capacity problem. Teams will either need to adopt more automated, modern tooling or risk falling behind.
Operationalizing MFP at Scale
The teams that manage MFP effectively will have the ability to track activity at the claim level, reconcile across systems, and identify issues early.
Plenful’s MFP Intelligence solution is designed to support that work. As a designated TPSE, our solution automates reconciliation and increases visibility around MFP refunds to reduce the administrative burden on pharmacies.
Plenful’s MFP Intelligence solution will:
- Access MTF data and remittance information on behalf of pharmacies through the MTF as a TPSE
- Reconcile expected vs. received MFP refunds at the claim level
- Identify duplications or credits in scenarios where both MFP and 340B apply
- Provide clear, claim-level visibility and reporting within executive 360 dashboards so pharmacy leaders can confidently manage revenue timing and cash flow, and feel prepared to report key learnings
Here’s what one of our partners, Henry Ford Health, has to share about their experience with MFP Intelligence:
“MFP reconciliation has become one of the most important operational priorities for our team,” said Alex Mansour, Director and 340B Compliance Officer at Henry Ford Health. “Plenful gives us a centralized command center to consolidate claims data, flag discrepancies, and track whether expected MFP refunds are being received. We’re able to surface and act on missing refunds much faster. That visibility helps protect the financial integrity of our pharmacies while significantly reducing manual work.”
MFP is a complex program that we’ve been following closely. I’d welcome the opportunity to connect and share more about what we’ve learned through our partners and how they’re recognizing value from Plenful.
You can read more about MFP Intelligence and hear real feedback from our partners in our recent coverage with Becker’s Hospital Review.
Tim L’Hommedieu is the Senior Vice President of Pharmacy at Plenful. He can be reached at tim@plenful.com, or here on LinkedIn.
