Implications for Duplication with the 340B Channel

On October 2, 2024, the Centers for Medicare & Medicaid Services (CMS) released final guidance on effectuation of the maximum fair price (MFP) for 2026 and 2027. The final guidance provides new insights into CMS’ expectations for effectuation and additional details on the role of the Medicare transaction facilitator (MTF). The final guidance leaves unanswered, however, the question of how to prevent the payment of duplicative MFP and 340B discounts.