NHIA submitted comments to CMS on its Draft Medicare Transaction Facilitator (MTF) Agreements, which will be used to implement negotiated prices for drugs under the Medicare Drug Price Negotiation Program. NHIA concurs with the position of National Community Pharmacy Association (NCPA) and others and is concerned with the effects some of CMS’ operational policies will have on dispensing entities. NHIA encouraged the agency to reduce financial and administrative burdens on dispensing entities through steps such as eliminating the need for dispensing entities to operate at a cashflow deficit while they wait for MFP refund payments from multiple manufacturers, requiring manufacturers to utilize a standard payment process so MFP refunds can be tracked in a less burdensome manner, and eliminating the Part D participation requirement that dispensing entities enroll with the MTF Data Module Contractor.