MEMBER ALERT: Upcoming Medicare Part D
Contracts and MFP Drugs in 2026
Background:
Starting in 2026, the Inflation Reduction Act's Medicare Drug Price Negotiation Program (MDPNP) will set Maximum Fair Prices (MFPs) for 10 brand-name drugs. These lower, negotiated prices will impact how pharmacies are paid.
Key points for independent pharmacies:
You'll see new 2026 Part D network contracts from PBMs referencing "MFP drugs." These are the first 10 drugs for which CMS negotiated lower prices from manufacturers (15 more in 2027, including Ozempic).
Your pharmacy will be required to participate in the MDPNP for any Part D plan/network you choose to participate in.
Payment and refund structure:
PBMs can reimburse no more than MFP + a dispensing fee.
Manufacturers must refund pharmacies the difference between MFP and the pharmacy's acquisition cost.
CMS suggests a standard refund of WAC - MFP, but manufacturers can choose a different formula.
Manufacturers have 14 days to pay the refund after a 7-day window for plans to submit claim data to CMS. Delays may cause pharmacies to wait 21+ days for reimbursement of manufacturer refunds, creating cash flow risks.
Enrollment and logistics:
Pharmacy enrollment in the MDPNP starts June 9 via the Medicare Transaction Facilitator (MTF). Please note that you will have to sign the dispenser agreement to enroll in the MTF (see here for the agreement); it includes onerous terms that you should be aware of and review with your own attorney.
Pharmacies can indicate if they have cash flow concerns, which may qualify them for financial relief from manufacturers.
Manufacturers aren't required to use the MTF's payment module, so you may have to deal with multiple refund sources for different manufacturers.
Urgent considerations:
You will be asked to decide whether to join 2026 Part D networks before you know the manufacturer refunds, because manufacturers are not required to release their refund amounts until September.
Expect short opt-in/opt-out PBM contract deadlines.
Read all contract terms carefully and stay in touch with your PSAO if applicable.
NCPA resources like the Contract Evaluation Best Practices guide can help.
NCPA's position:
NCPA is pushing:
PBMs to pay MFP + fair dispensing fee (no price concessions)
Manufacturers to refund at WAC - MFP
Manufacturers to refund within 14 days of fill date
NCPA has warned CMS many times that without these three conditions, the MDPNP will likely fail.
Stay alert. Stay informed.
NCPA is fighting for changes to protect independent pharmacies and will continue to update you.
Check your email for CMS notices and review the CMS resource page.
Watch for more updates from NCPA.
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