Part II: The Medicare Transaction Facilitator Turns a Negotiated Drug Price Into an Auditable Claim-Level Event: Two MTF Modules, a Seven-Day PDE Feed and the Part B NDC Identity Gap

CMS’s draft MTF guidance is the most detailed operational document in the entire IRA drug pricing rollout, and almost everyone is going to misread the 14-day clock.

The Medicare Transaction Facilitator is not the payer. It is a data layer. The underlying claim pays the usual way. The MTF identifies eligible events and ships claim-level data to the manufa…