Up to 20% of Expected MFP Refunds Are Missing: What We’re Seeing in Reconciliation

Recap of Plenful's MFP Intelligence & GFI Agent Solution Showcase, presented by Tim L'Hommedieu, PharmD, MS, SVP of Pharmacy, and Matt Krah, Principal Solutions Consultant.

Medicare's Maximum Fair Price (MFP)  went live January 1, and the MTF is already processing roughly $350 million in refunds a week, approaching $10 billion since the program started. Reconciling these refunds is another story.

Plenful customers are consistently seeing a gap of 15 to 20% in refunds that arrive short, late, or never get effectuated at all. Almost none of it gets disputed. As Tim L'Hommedieu, PharmD, SVP of Pharmacy at Plenful put it during the webinar, "many of you may say, ‘hey, I'm seeing a lot of issues with my claims,’ but fewer than a half a percent of all the claims filed actually have a GFI. So, if you aren't filing those, CMS is, in essence, in the dark.” A GFI is the only signal CMS gets that a refund was wrong, so with almost none on record, the program looks like it is effectuating correctly 99% of the time.

MFP reconciliation: opportunity for breakdown at every handoff

MFP reconciliation today requires manually cross-referencing the MTF, Beacon, the pharmacy management system, and your TPAs. None of those systems talk to each other, meaning a missing refund only surfaces when someone goes looking for it. One claim at a time.

Manufacturers add a second failure mode - they have little visibility into which transactions are actually 340B. One method is the prescriber's NPI: if the credential ties to a covered entity, the refund gets denied.

Matt Krah, Principal Solutions Consultant at Plenful, described a particularly stark case: a pharmacy that has not participated in 340B in over three years is still having MFP refunds denied on the grounds that 340B providers filled them. As he put it, "it is definitely an imperfect system.”

Manufacturers treat the 120-day GFI window as a deadline to close, not open

A Good Faith Inquiry (GFI) has a 120-day window, and as Tim explained: "most of the manufacturers are treating the 120-day window as the deadline to close the GFI, not just open it." One offers a 30-day extension. When supporting documentation is complete, manufacturers are resolving GFIs in three to ten days.

His advice: File ASAP.

Filing is where the hours go. Someone logs into Beacon's Resolution Center, works through the wizard for a single claim, attaches documentation, and waits. When the manufacturer responds, it usually asks for the purchase invoice and associated claims through ESP before releasing payment. A second submission, in a second system. Rinse and repeat for every claim.

And this is the program at its smallest.

MFP expands to add 30 drugs by 2028

"You can think of 2026 as the warm up," Tim said. "When we flip that calendar to 2027, the intensity really starts."

Today two drugs carry refunds over $1,000: Enbrel and Stelara. Nine of the next 15 will, and the additions include the GLP-1s. Those therapies were used by more than 5.3 million Part D beneficiaries in 2024 and accounted for over $40 billion of Part D spend, roughly 15% of gross drug costs.

"If the MFP program hasn't felt financially material for your pharmacy team yet," Tim said, "consider this your friendly nudge to probably start planning now, because 2027 is going to make it very hard to look the other way."

The same date starts a second program on the same team. HRSA's revised 340B Rebate Model Pilot, announced July 31, is proposed to take effect January 1, 2027 for approved manufacturer plans, and covered entities will have to submit claims-level data to receive rebates. That is more than double the work on the same staff, with the same processes in place today.

It doesn’t stop there. Part B drugs will join the program in 2028, with CMS's first draft guidance published July 16 and comments due September 18. The complexity is only going to continue growing.

How MFP Intelligence automates MFP reconciliation end to end

MFP Intelligence surfaces claim-level discrepancies: missing refunds and potential duplicate discount risk. Because Plenful normalizes data across multiple pharmacy systems, teams submit from one place instead of three, the same foundation behind our 340B audit and optimization work.

With MFP Intelligence and GFI Agent, pharmacy teams can:

• Automate the submission of GFIs directly in Beacon's Resolution Center for every eligible claim
• See denied GFIs flagged for review, with the manufacturer's rationale surfaced in Plenful's task management UI
• Allow Plenful to locate and associate the purchase invoice tied to each claim via direct integrations with wholesaler EDI feeds
• Automatically submit details associated with GFIs to ESP, fully automated or with a human in the loop on invoice-claim review
• Track every submission as refunds are approved, denied, or still pending

Alex Mansour, Director and 340B Compliance Officer at Henry Ford Health, described the result as a centralized command center that protects the financial integrity of their 340B program.

Get MFP reconciliation automated before IPAY 2027 starts

January is closer than it sounds, especially for a team that already feels stretched. The drug list doubles, a meaningful share of the refunds are more than $1,000, and the 340B rebate pilot is positioned to start on the same day.

Tim sees MFP heading down the same road 340B did: "the daily operations are complex and it has a direct impact on your bottom line. And ultimately, I think it's really not very well understood by a large number of the healthcare executives in play." Managing it without a platform, in his view, is going to be really difficult. He made a similar case for where AI is already working in 340B programs at 340B Health's Summer Coalition Conference.

If you want to size the gap before then, pull your last 90 days of expected MFP refunds and compare them against what the MTF shows you received. Few teams have run that comparison, and whatever it surfaces today is roughly what 2027 will multiply.

Bring us your numbers. Request a 1:1 with our MFP team, and we will run that comparison with you and show you where refunds are going missing.