What MFP is quietly costing 340B covered entities
The Medicare Maximum Fair Price, or MFP, program is creating new complexity for 340B covered entities and pharmacies. For organizations already managing a high-volume, high-stakes operating environment, the added pressure is not just regulatory. It is operational, financial, and cross-functional.
Anaila Moreau, 340B Consultant at Accelerate Pharmacy Solutions, recently sat down with Tim L’Hommedieu, SVP Pharmacy at Plenful to talk through what they are seeing across covered entities.
The pattern is consistent: MFP is introducing new claims, pricing, and reconciliation challenges that many pharmacy and finance teams are still working to operationalize.
Why is MFP now top of mind?
For 340B teams, the challenge starts with data. Manufacturers often do not have all of the claim-level information needed to determine 340B eligibility and acquisition price accurately during the MFP effectuation process. That gap can lead to several downstream issues, including:
- Missing MFP refunds on eligible claims.
- Duplicate discounts when a 340B claim also receives an MFP refund that should not have been paid.
- Incorrect refund amounts when the acquisition price used in the effectuation process does not align with the actual price.
Missing data and overlooked claims directly impact revenue and cash flow. As these in-house pharmacy claims become ineligible, teams face mounting workloads to identify and resolve discrepancies.
How MFP affects different covered entity structures
The impact of MFP can vary depending on how a covered entity is structured.
For covered entities with contract pharmacy relationships, MFP raises important questions about claim eligibility, carve-in and carve-out decisions, refund accuracy, and the long-term financial viability of existing arrangements.
For covered entities with in-house pharmacies, the challenge can be even more immediate. Organizations that dispense a high volume of both 340B-eligible and non-340B prescriptions may be more exposed to refund discrepancies, duplicate discount issues, and reconciliation burdens.
This work does not sit neatly with one team. Pharmacy leaders, 340B teams, revenue cycle professionals, and finance stakeholders may all play a role in this process and without a clear strategy, these tasks can quickly become resource intensive.
MFP is not a one-time adjustment
MFP is not a short-term development. As noted in the discussion, additional drugs are expected to be added in future years, and the expansion into Part B will introduce additional complexity for many organizations.
That means covered entities will need repeatable, scalable processes.
So what does a scalable process look like?
So what does a scalable process look like?
For leaders navigating MFP, the need is not only to understand the policy. It is to build an operational model that can keep pace with it. Tune into this discussion between Anaila Moreau, and Tim L’Hommedieu.
Accelerate Pharmacy Solutions partners with health systems on 340B program optimization, compliance, and audit readiness. Our 340B consulting team can help covered entities work through the operational and reconciliation challenges MFP is introducing, from claim-level data alignment to workflow improvements and full program management.
