CMS Opens Public Comment on New Medicare Transaction Facilitator (MTF)

CMS is asking the public to weigh in on the Medicare Transaction Facilitator (MTF), the system that carries negotiated drug prices from manufacturers to the pharmacy counter.

Medicare drug price negotiation raises real concerns for the research and innovation that patients depend on. But the policy is moving forward, so the practical questions matter now.

Here is the concern. The MTF is built to make sure pharmacies receive the negotiated price, usually through a manufacturer refund. That is important work. But it does not, on its own, guarantee that the patient feels the savings rather than an insurer, a pharmacy benefit manager (PBM), or another middleman absorbing them along the way.

Right now, there is an opportunity to determine whether anyone can even see where the savings land. That is why this comment period matters, and why your voice belongs in it.

Comments are due September 22, 2026.

*Submit online through Regulations.gov. A sample STARR comment is available below to guide your own.

What Is CMS Requesting?

On July 24, 2026, the Centers for Medicare & Medicaid Services (CMS) published a 60-day notice in the Federal Register under the Paperwork Reduction Act, inviting the public to comment on the information it collects to run the Medicare Transaction Facilitator. This is the revised version of the collection that will govern the program going forward, including the addition of Part B providers.

Under a PRA notice, CMS is specifically asking whether the collection is necessary and useful, whether the burden estimate is accurate, and how to improve the quality and clarity of what is collected. That scope is exactly where our concern fits: are the forms designed to actually confirm that negotiated savings reach patients?

The Issues, and Why Your Voice Matters

Here is a plain-language look at how the current system works and where public comment can make a difference:

Issue	What the proposed system does now	Why your voice matters
Savings reach the pharmacy, not clearly the patient	The MTF confirms that dispensing entities and providers receive the Maximum Fair Price, mostly through retrospective manufacturer refunds. It stops at the dispensing-entity level.	CMS needs to hear that confirming pharmacy reimbursement is not the same as confirming patient benefit. Real-world voices make that case better than a burden estimate can.
No clear line of sight to beneficiary impact	The forms are not structured to show how a negotiated price relates to what a patient actually pays at the counter.	Comments can ask CMS to capture information that supports monitoring beneficiary-level impact, so the program can be measured against its real purpose.
Middlemen can absorb the savings	Nothing in the MTF itself guarantees that plans or PBMs pass negotiated savings through to beneficiaries.	A discount does no good if it disappears upstream. Documenting that risk on the record gives CMS a reason to act.
Complaints form may miss patient-facing problems	The Complaints & Disputes form is a valuable early-warning tool, but its categories focus on transactions between manufacturers and dispensers.	Ask CMS to make it easy to flag when beneficiaries are not seeing expected savings or face access delays from intermediary practices.
Mental health drugs are on the horizon	The MTF covers Part B and Part D selected drugs. Psychiatric medications could move through this same machinery in later negotiation cycles.	If the mental health community does not comment now, the design will be shaped without our populations in mind.
Deadline: September 22, 2026	Submit electronically at Regulations.gov, docket CMS-2026-2608. Reference Document Identifier CMS-10912 / OMB Control No. 0938-1483. A letter can be attached.	CMS weighs both the volume and the specificity of comments. Even a brief, focused submission adds to the record.

Good news worth noting: the revised collection cuts the estimated paperwork burden by more than two thirds compared to the original. CMS is already moving to simplify. That makes this the right moment to say: keep simplifying, and make sure the savings reach patients.

——————————————-

Once you click on the SUBMIT COMMENT button, you will see a confirmation box pop up.

Advocates, patients, caregivers, and community organizations all have standing to comment. Real-world perspectives on how drug costs shape access to care, and on whether patients actually feel the savings a negotiated price is supposed to deliver, are exactly what CMS needs to hear.

Why This Matters for Mental Health Research

People living with mental health conditions are among the most underrepresented in clinical research and among those who face the most practical barriers to care. Access to affordable medication is part of that picture. When a policy is meant to lower the cost of a drug, the people it is designed to help should be the ones who feel the difference.

STARR is not endorsing the Medicare Drug Price Negotiation Program. Our concern is different and specific: since the program is moving forward, the system built around it should deliver value to patients, not just move money between other parties. That is a message CMS will only hear if the community sends it.

Comments are due September 22, 2026.

How to Comment

Go to Regulations.gov, docket CMS-2026-2608.
Reference Document Identifier CMS-10912 / OMB Control No. 0938-1483.
Type a short comment, and/or attach a full letter as a PDF or Word file.
When prompted, you can submit as an organization or as an individual.
Submit before September 22, 2026. Remember that comment text is public.

Use our comment below as a starting point (click to open). Feel free to adapt it or submit your own perspective.

This issue is part of STARR’s broader work on access and trust in mental health clinical research. It connects to our advocacy on drug pricing, patient access, and the role of public-private partnership in bringing new treatments to the people who need them.