Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics #00311

Submission Number:
Jacqueline Gallery
Initiative Name:
Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics
Dear Sirs and Madam, I am a neighborhood pharmacist serving a rural community with a population of patients that includes newborns to great-grandparents. I have been a pharmacist for 23 years and owned a pharmacy for more than four years. As a pharmacist, I am the patient's trusted partner and last line of defense for prescription medication care. PBMs are compromising that trust by forcing the use of contractual "gag clauses" that require my silence when I see a less expensive, but equally effective alternative to a prescribed drug. Although drug prices are skyrocketing, non-PBM-owned pharmacies are being reimbursed drastically below cost. Meanwhile, PBMs force patients to use PBM-owned mail order and PBM-owned retail pharmacies (like CVS and Express Scripts) in order to save on their copays. This is anticompetitive behavior that downgrades pharmacy and the seriousness of prescription medical treatment, as if buying prescription drugs were the same as buying simple merchandise. PBMs are not the helpful, cost-savings third-party administrators they portray. They are industry middlemen profiting at every stage of the prescription drug supply chain from the manufacturers and the dispensers to the plan payers and patient. They are driving up drug prices, promoting the use of certain drugs over others, forcing medical providers to remain silent and costing patients and taxpayers tens of millions of dollars every year. 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 the out-of-control cost of healthcare. We care about our patients like family not just a number. We take time to counsel and advise them on their medications. This is not a service the big box stores or mail order houses will take time to perform. This improves patient outcomes and quality of life. The PBM's will run small independent pharmacies out of business, if this happens the wait times and price increases will be out of control. We are a small pharmacy in 2017 we have paid over $7000.00 in DIR fee's. These funds should stay in our community and not into the hands of PBM's executives. Your help is needed to stop these practice's by the PBM's! Sincerely, Jacqueline S. Gallery, D.Ph.