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 reimbursementWhy 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 concernsHow litigation has temporarily paused the rebate pilot, preserving upfront 340B discounts—for nowWhat covered entities must do today to prevent MFP duplicate discounts and confirm MFP rebates are handled correctly for non-340B prescriptionsWhy vendor limitations may require manual controls and enhanced monitoring in the near termEven 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/