Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics #00388

Submission Number:
00388
Commenter:
Keval Patel, Pharm.D.
State:
Florida
Initiative Name:
Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics
"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." The pending CVS Health merger with Aetna, which will tip the balance of power to CVS in an environment that already fosters abuse of power without checks and balances CVS/Caremark's unannounced change to MAC reimbursements beginning Oct. 26, which resulted in even deeper cuts to reimbursements that were already far below cost How PBMs profit by keeping all or most of manufacturers' rebates rather than passing them on to plan payers, defeating the purpose of the rebate The conflict of interest arising from PBMs who administer drug benefit plans, and then mandate plan enrollees use PBM-owned pharmacies, including mail order, to "save money" on copays Patient choice is limited and their rights infringed upon. Patients who cannot fill a prescription from their local neighborhood pharmacy may not be up to the task of seeking out a new pharmacy, choosing instead to forgo their medications and risk their health.