Comments on How Pharmacy Benefit Managers (PBMs) affect Smaller Pharmacies and Consumers (ID FTC-2022-0015-0001)

The business practices of Pharmacy Benefit Managers (PBMs), who advise health plans in developing their drug formularies, are increasingly controversial, especially with independent pharmacies. These controversies have driven the Federal Trade Commission (FTC) to request public comments on PBM business practices. Pioneer Institute Senior Fellows William Smith and Robert Popovian submitted public comments about PBM business practices.

While much of the controversy at the FTC over PBMs was driven by independent pharmacies, Pioneer’s comments raised concerns that PBM business practices were driving up out-of-pocket costs for patients and making some medicines unaffordable. While Pioneer is sympathetic to the plight of independent pharmacies, we are most concerned that PBM practices make medicines unaffordable for a growing number of patients who, when faced with high out-of-pocket costs, decline to fill their prescriptions. In their public comments, Pioneer recommended that PBM discounts be passed along to patients when they are meeting their deductible or coinsurance requirements.

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