Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics #00242

Submission Number:
00242
Commenter:
DM Wallbaum
State:
Wisconsin
Initiative Name:
Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics
As a pharmacist of 20 years, I would like to submit a few observations about the PBM industry. 1. Drug prices are skyrocketing, yet non-PBM-owned pharmacies are being reimbursed below cost. PBMs often force patients to use PBM-owned mail order, PBM specialty pharmacies and PBM-owned retail pharmacies (like CVS) in order to save on their copays. This is anticompetitive behavior that downgrades pharmacy and the seriousness of prescription medical treatment. 2. There are often less expensive generics readily available but PBM's require the more expensive Brand-name products that generate "rebate" dollars for the PBM's which are not passed through to the customer. 3. Non-transparent MAC and WAC price grids. The reimbursement drug costs are from a magical list that each PBM has developed. The WAC cost that a PBM provides is OFTEN much lower than the cost a pharmacy can get from their wholesaler. When asked where that specific drug cost is available, there is no real answer. It could be last month's cost, a price that a large corporate pharmacy can buy at or a price found from a stock that is not widely available. The FTC's mission is to protect consumers and prevent anticompetitive business practices. On behalf of patients, drug plan sponsors and small business pharmacies who depend on trusting relationships with their patients, please intervene in these unregulated entities and break up the enormous power PBMs have over patients and pharmacies. Thank you for your consideration.