Update on Effectuation of the Maximum Fair Price in 2026 and Outlook for 2027

Since January 1, 2026, the Maximum Fair Price (MFP) has been available to pharmacies and other dispensing entities (collectively, “pharmacies”) dispensing a subset of ten selected drugs to beneficiaries covered by Medicare Part D. The MFP has been offered in the market through the following process:

• The pharmacy acquires the drug from a wholesaler or distributor or directly from the manufacturer, dispenses it
  to the Part D beneficiary, and bills the beneficiary’s Part D plan.
• The beneficiary’s Part D plan reimburses the pharmacy at the MFP plus a dispensing fee and transmits data on the dispense to the Centers for Medicare and Medicaid Services (CMS).
• CMS, through a contractor known as the Medicare Transaction Facilitator (MTF), transmits the dispense data to the manufacturer and its rebate processing partner, the Beacon MFP platform.1
• Per CMS guidance, the manufacturer has fourteen days from receipt of data to 1) determine if the price paid by the pharmacy to acquire the drug exceeds the MFP, and 2) transmit the data back to CMS indicating whether a rebate will be paid to bring the pharmacy’s net acquisition cost to the MFP.
• The MTF disburses manufacturer rebates to pharmacies. Where pharmacies have opted in, the disbursement is done using electronic funds transfer (EFT).