Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics
Dear Sir, or Madam, I have been an independent pharmacy owner for over 50 years. During the course of those years it has been my privilege to serve my community in various way's that a large chain never would. As a small business owner, these large PBM's are a detriment to us, and the patient's that they claim to serve. I am a patients trusted partner and last line of defense for prescription medication. PBM's are compromising that trust by forcing the use of contractual "gag clauses" that require my silence when I see less expensive, but equally effective alternative to prescribed drug. I don't know any other business where one is expected to purchase products (medications) at a certain cost, and then turn around and dispense, and be reimbursed at a lower rate then purchased, and on top of that later down the stream, charge us a bogus DIR fee to further extract monies from us. And although drugs 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 co-pays. This is noncompetitive behavior that downgrades pharmacy and the seriousness of prescription medical treatment. These PBM"s are fleecing the healthcare in America. I had an experience where a claim was being adjudicated at a very low cost. When I contacted the patient's plan, I was told that they had paid the PBM one price, and we were reimbursed way less then they paid. I have kept records of that transaction. This is not an isolated case, this is happening in this industry on a daily basis. How do we tolerate this type of behavior from companies who again are getting over on the american people, government. PBM's are not the helpful, cost-saving third-pary administrator they portray. They are industry middlemen profiting at every stage of the prescription drug supply chain from the manufacture and the dispensers to the plan payer's to the patients. hey 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 anti competitive 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.