Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics #00387

Submission Number:
Heather Radel
Initiative Name:
Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics
I am a independent community pharmacy manager serving a very poor urban population of patients that includes newborns to great-grandparents. My family has owned this business for almost 40 years. We are our patients' 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 (usually a generic). We pack patients' medications in weekly packs and deliver them to them for free, all while PBMs are reducing our reimbursements and taking bigger profits. 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) 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 dish soap or paper towels. 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. Please listen to independent small businesses as well as the huge corporations that have your ear. Many of us are on ground zero and are seeing the outcomes of PBM abuse on a daily basis.