When a pharmacy fills a Medicare Part D prescription for a drug with a negotiated maximum fair price (MFP), it's paid the lower MFP and then waits for the manufacturer to refund the difference. When that refund arrives late, short or not at all, it hurts cash flow, especially for independent pharmacies. Here's how to track what you're owed and what to do when something's missing.
When should the refund arrive?
CMS says refunds reach the pharmacy's bank account within 21 days of the date of service on average. That's up to 7 days for the Part D plan's claim data to reach the Medicare Transaction Facilitator (MTF), up to 14 days for the manufacturer to respond, and up to 5 banking days for payment. Some claims move faster and some slower. A claim that's well past those windows deserves a closer look.
How much should it be?
The expected amount is the Standard Default Refund Amount (SDRA): WAC minus MFP, times the quantity dispensed. A manufacturer may pay a different amount if it keeps documentation explaining why, so a short refund isn't always an error. The remark code on the payment (for example N909 or N917) usually shows why.
Five steps to reconcile
- Set up electronic payment.Enroll in the MTF Data Module with current banking details to get electronic payments; without it, refunds come by paper check. New enrollments, and any banking or payment-relationship change, start a 7-day verification period. Log in at least every 60 days so your CMS account stays active.
- Pull two reports.The 835 electronic remittance shows what was paid, and the MTF Claims Tracking Report shows how each amount was calculated. Use them together. One payment can cover several manufacturers, and chains are paid at the payee level, so match by NPI.
- Read the adjustment codes.CARC 307 (Medicare MFP SDRA Adjustment) flags an MFP refund adjustment, and it always comes with one of seven remark codes that explain why: N907 to N911, N917 or N918. Two are worth knowing: N910 means a refund can't be provided for the claim right now and you should contact the manufacturer directly about your eligibility, and N907 means the refund was withheld because the claim was identified as 340B-eligible with a ceiling price below the MFP. If a claim flagged as 340B isn't actually 340B, confirm with the covered entity or its TPA, then file a GFI (step 4).
- File a Good Faith Inquiry (GFI).A GFI is the first step when an MFP refund is denied or lower than expected; CMS expects you to try to resolve it with the manufacturer before going to the MTF. For 2026 drugs, manufacturers use Beacon to handle GFIs, and you need a registered Beacon MFP account to file one. In Beacon's Resolution Center, search by the claim's ICN, follow the prompts and upload documents that support the claim's status and pricing. File one GFI per ICN. You can't open a second GFI for the same refund, so if you find new information later, ask Beacon support to reopen it. If the GFI is approved, the full or additional refund is paid through the MTF. Each manufacturer's MFP Effectuation Plan, on the Manufacturer Dashboard in the MTF Data Module, also explains its process.
- Escalate if needed.If the GFI is denied or doesn't resolve the issue, file a complaint or dispute through the MTF Help Desk portal. CMS expects proof that you tried to resolve it first, so include your GFI. Include the NPI, the claim's internal control number (ICN), the drug and screenshots, and use separate forms for separate issues (similar concerns can go on one form). The MTF Help Desk is at 1-877-683-4457.
340B claims and MFP refunds: what changes January 1
Each MFP claim goes one of two ways: the pharmacy gets the MFP refund, or the covered entity gets the 340B price. Not both. If the claim really is 340B, the pharmacy gets no MFP refund, but it should still be paid its dispensing fee and have the drug replenished. If the claim isn't 340B, file a GFI (step 4).
For drugs in HRSA's 340B Rebate Model Pilot, the covered entity gets the 340B price as a rebate through Beacon. Manufacturers differ on whether the covered entity's 340B rebate or the pharmacy's MFP refund gives way when both could apply.
| Manufacturer | When a 340B claim is also an MFP claim |
|---|---|
| Merck, Pfizer, Teva, Amgen | Pays the 340B rebate to the covered entity and adjusts or withholds the pharmacy's MFP refund |
| AbbVie, AstraZeneca, BMS | May reject the 340B rebate when the MFP is lower than the 340B ceiling price; when the ceiling price is lower, the MFP refund is adjusted or denied |
| GSK | Handles it on the MFP side first, but reserves the right to reject 340B rebates later |
| Astellas, Boehringer Ingelheim | Plan doesn't say |
These rules come from each manufacturer's HRSA-approved plan and can change. Contract pharmacies may want to review their cash-flow assumptions and discuss contract terms with their covered entity partners and advisors.
Swipe sideways to see the full chart.
Register with Beacon MFP before you need a GFI
Manufacturers use Beacon MFP to check refund requests and work out refund amounts for all 2026 selected drugs; the refunds themselves are paid through the MTF. Registration is free for dispensing entities and optional, since refunds come either way. Registering gives you near-real-time refund status, downloadable reports and the ability to open a good-faith inquiry, which requires registration.
How Secure340B can help
Secure340B's MFP Reconciliation service matches claims to refunds, reviews 340B flags, flags discrepancies and supports good-faith inquiries. Covered entities with their own pharmacies can see MFP Reconciliation for Owned Pharmacies. You can also take the free MFP Rebate Readiness Quiz or email MFPsupport@Secure340B.com.
Information current as of October 31, 2026, based on CMS's MTF FAQ for pharmacies (updated April 2026), Beacon's MFP FAQ and the HRSA-approved manufacturer plans. This is general education, not legal advice. Sources: CMS MTF FAQ for pharmacies; Beacon MFP FAQ; HRSA 340B Rebate Model Pilot Program.