The Inflation Reduction Act (IRA) is bringing major changes to the pharmaceutical landscape—especially for dispensers serving Medicare patients. One of the most impactful elements is the Maximum Fair Price (MFP) provision, which allows Medicare to negotiate drug prices directly with manufacturers
As the implementation timeline advances, pharmacies must prepare for new regulatory, operational, and system requirements. This checklist offers a clear guide to help dispensers assess readiness and stay ahead of compliance demands.
Regulatory and System Readiness
- Review CMS Guidance
Familiarize yourself with the latest MFP updates and deadlines directly from CMS. Understanding the scope of the provision is step one. - Confirm Authorized Signers
Ensure your designated CMS contacts are current and authorized to handle key submissions or data exchange. - Understand NCPDP Requirements
Review updates from the National Council for Prescription Drug Programs (NCPDP) related to claim formatting and drug identification under MFP.
Operational & Dispensing System Preparation
- Coordinate with Your Dispensing System Vendor
Your system should support MFP reimbursement logic. Confirm that pricing and claims modules are configured for compliant processing. - Enable Claim Flagging Capabilities
Verify whether your dispensing system or third-party software can flag drugs subject to MFP for audit or operational purposes. - Discuss Receivable Balance Handling
Talk to your dispensing system vendor and/or your switch to understand how they will handle and reflect the receivable balance between WAC and MFP. This is essential for reconciliation, reporting, and operational accuracy.
Internal Team Alignment
- Educate Your Staff
Ensure that billing, compliance and pharmacy operations teams understand MFP’s impact and know how to respond. - Assign Point People
Designate team leads to manage vendor relationships, oversee CMS/NCPDP communications, and coordinate internally.
Key Dates and Future Planning
- Mark Your Calendar: Registration opens on June 9th, 2025
This is a critical milestone for registration and potential data exchange requirements. Stay alert for CMS and NCPDP communications. - Track Drug Eligibility Changes
The list of MFP-targeted drugs will expand in future years. Ongoing monitoring of CMS announcements is essential.
Need Help Navigating These Changes?
Whether you're a current client or just exploring your options, Inmar is ready to help you interpret MFP guidelines, optimize your dispensing operations, and stay compliant with evolving federal requirements.