Cracking the MFP Code: What is the role of the MTF?

What is the role of the Medicare Transaction Facilitator (MTF)?

Recognizing the complexities of the IRA’s MFP regulations, CMS has introduced solutions to help manufacturers and dispensers manage the program effectively.

CMS will select a Medicare Transaction Facilitator (MTF) to facilitate the exchange of data and payments to help administer the MFP program for the selected products. The MTF is separated into two aspects, the MTF Data Module (MTF DM) and the MTF Payment Module (MTF PM). 

1. MTF Data Module (MTF DM): Mandatory participation
   1. Provide claim-level data elements confirming that the drug was dispensed to MFP-eligible individual 
   2. Initiate the 14-day prompt payment window
   3. Collect payment elements indicating rebate payment and amount
      1. Will include the Standard Drug Rebate Amount (SDRA) calculated based on WAC minus MFP
   4. Generate ERA for payments made through MTF PM
2. MTF Payment Module (MTF PM): Optional participation
   1. Provide manufacturers with a mechanism for transfer of funds (both electronically and by paper check)
   2. Credit/debit ledger system to track the flow of MFP refunds, handle reversals, adjustments, and claim revisions 
   3. MTF PM will make available payment information to manufacturers who choose to make payments outside of the MTF PM

It’s important to highlight that all manufacturers and dispensers are required to participate in the MTF DM, while the MTF PM is optional. However, manufacturers are ultimately responsible for calculating the correct discounts, a crucial point given the involvement of multiple price points and cross-program interactions. While CMS has established transaction facilitators to manage the exchange of information, payment details, and even specify rebate amounts, relying solely on WAC for payments creates significant challenges due to the numerous other price points involved. Although the MTF DM will calculate the rebate amount based on the SDRA, manufacturers aren’t required to use the SDRA to calculate the MFP refund. Even without considering cross-program interactions, the MFP program itself involves several top price points. As a result, manufacturers will likely require additional systems—possibly multiple—beyond the MTF PM to effectuate MFP accurately.

Cross program interactions

Throughout this blog series, we’ve explored the complexities of managing cross-program interactions between MFP, 340B, and other discount programs. While the MTF PM helps manufacturers in calculating an MFP discount, it doesn’t address the challenges posed by overlapping programs. For example, according to CMS guidance, when a drug qualifies for both 340B pricing and MFP, manufacturers are required to charge the lower of the two prices. This necessitates a solution capable of evaluating program intersections. However, the solutions proposed by CMS are built only for MFP, offering no visibility into other discount programs.

Ambiguity surrounding the MTF

The MTF implementation is surrounded by uncertainty, with several critical questions still unanswered. Key details, such as the vendor, the scope of data integrity within the MTF DM, and the mechanics of payment effectuation, remain unclear. Data security and payment processes will be essential considerations for manufacturers when forming an MFP plan. Additionally, thoroughly vetting a platform of this scale requires significant time and attention from multiple stakeholders within an organization. With a September deadline to submit their plan to CMS, manufacturers face a tight timeline that may not allow for a proper evaluation of the MTF PM, especially because it has yet to be announced. 

We understand that there’s a lot to consider as you prepare to implement MFP. Our team of experts is available to help simplify the process and provide more detailed guidance. If you’d like to speak with one of our Subject Matter Experts, please submit your contact information here, and we’ll get in touch with you.