MFP + 340B in 2026: Duplicate Discount Risk, Rebate Pilot Pause & Compliance Readiness

Starting January 2026, the Inflation Reduction Act (IRA) will introduce Maximum Fair Prices (MFPs) for select high-cost Medicare Part D drugs—creating a new compliance intersection with the 340B Drug Pricing Program.

In Episode 11 of Katy’s 340B Compass, she walks through what these reforms mean for covered entities, including:

• What the MFP is and how it changes Part D reimbursement

• Why MFP and 340B discounts cannot apply to the same transaction (duplicate discount risk)

• HRSA’s proposed 340B Rebate Model Pilot and why it raised major operational and financial concerns

• How litigation has temporarily paused the rebate pilot, preserving upfront 340B discounts—for now

• What covered entities must do today to prevent MFP duplicate discounts and confirm MFP rebates are handled correctly for non-340B prescriptions

• Why vendor limitations may require manual controls and enhanced monitoring in the near term

Even with the rebate pilot delayed, the compliance obligation remains; covered entities must actively prevent duplicate discounts and maintain audit-ready documentation.

📥 Download the Slide Deck (Episode Toolkit)https://virtue340b.com/ira-mfp-340b-rebate-pilot-program-guide-toolkit/