Navigating MFP Implementation: Stakeholders Weigh IRA Challenges at Asembia 2025
At Asembia 2025, industry experts from Cencora gathered to dissect the pressing challenges and evolving implementation framework of the Inflation Reduction Act’s (IRA) Maximum Fair Price (MFP) provision. The session—moderated by Tyler Novotny, Vice President of Market Economics—delved into the 2 prevailing models for MFP effectuation, the policy landscape, and the anticipated ripple effects across the drug supply chain.
Regulatory Momentum and Political Context
Whitley Quan, Public Policy Manager at Cencora, opened with a policy update, highlighting an executive order from President Trump directing Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr to issue recommendations aimed at improving cost-saving projections and expanding transparency around the MFP process. While regulatory clarity has been slow to emerge, the Centers of Medicare and Medicaid Services (CMS) recently outlined critical timelines: manufacturers must submit effectuation plans by September 1, while enrollment for dispensing entities will run from January 1 to November 15.
Despite CMS’s recent uptick in engagement—including a data module demo and outreach to trade groups—Quan emphasized ongoing stakeholder uncertainty, citing a need for greater transparency and responsiveness from the agency.
Retrospective vs Prospective Models
Novotny introduced 2 CMS-compliant models for implementing MFPs:
Retrospective Refund Model: Pharmacies purchase drugs at traditional wholesale acquisition cost (WAC) but are reimbursed by Medicare Part D plans based on the lower MFP. Manufacturers then issue a backend refund to pharmacies to make up the difference, triggered via the Medicare Transaction Facilitator (MTF). This introduces potential cash flow gaps of up to 45 days.
Prospective Discount Model: Pharmacies acquire Medicare-covered drugs at the negotiated MFP price upfront, eliminating the need for retroactive reimbursement. While this approach simplifies payment logistics, it requires significant system changes and coordination across the distribution channel.
Manufacturer and Pharmacy Concerns
Caleb Debenham, representing Cencora’s Global Practice Solutions team, outlined 4 major concerns voiced by manufacturers:
- Compliance Risk: Ensuring adherence to CMS deadlines to avoid civil penalties for late payments.
- Operational Burden: Managing refunds for approximately 60 000 pharmacies, including dispute resolution and reconciliation.
- Duplicate Discounts: Risk of overlapping MFP and 340B discounts on the same claim, leading to potential legal exposure.
- Cash Flow Strain: Pharmacies—especially independents—may face unsustainable shortfalls waiting for reimbursement. Some report considering pulling out of MFP-eligible drug dispensing altogether.
To mitigate these issues, Cencora is developing a prospective solution enabling pharmacies to receive MFP-priced inventory upfront, with Cencora managing reconciliation, data collection, and communication with manufacturers.
Provider Perspective: Education and Economic Impact
Megan Law, senior director of portfolio accounts, shared feedback from provider interviews. The central concerns echo pharmacy issues: operational disruption, delayed reimbursement, and patient access risks. Many financially strained sites fear they may be forced to refer patients elsewhere, underscoring the urgent need for cash flow support and implementation tools.
Providers have responded positively to Cencora’s prospective model, seeing it as a pathway to smoother workflows and more predictable reimbursement. However, as Law noted, many practices feel they’re in “a sit and wait” mode until manufacturers finalize their effectuation plans.
Final Takeaways
With a tight timeline between the September plan submission deadline and the January 1, 2026, go-live date, all panelists agreed that education, infrastructure readiness, and responsible implementation are critical. As Novotny concluded, success will require careful planning to avoid concentrating undue burdens on any single stakeholder group in the supply chain.
“There’s no [one-size-fits-all] solution here that’s going to work for everyone,” he said. “It’s going to take careful thought, planning, and preparation to implement this in a way that’s responsible end-to-end.”
Reference
Novotny T, Debenham C, Law M, Quan W. Challenges in IRA maximum fair price effectuation: evaluating the retrospective and prospective MFP models. Presented at: Asembia 2025; April 29, 2025; Las Vegas, NV.
