Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics #00414

Submission Number:
00414
Commenter:
decandia
State:
New Jersey
Initiative Name:
Understanding Competition in U.S. Prescription Drug Markets: Entry and Supply Chain Dynamics
I am a community pharmacist serving a suburban population of patients that includes newborns to great-grandparents. I have been a pharmacist/owned a pharmacy for more than 25 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 (usually a generic) ..."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 ... We also see prices to patients increased $20-50 more for prescriptions cost only so the pbm can charge us back & collect that fee. The pharmacy makes no extra fee & the patient is paying an additional "premium" back to the pbm. The PBM's practices are increasing healthcare costs to the patient and the payers (commercial and government). The discounts received due to their volume are being shared partially with the payers with the highest percent going to their bottom line. Why should any industry have a safe harbor for kickbacks? At a time when drug prices are soaring, and the public is at risk of harm from shortages of critical medications and sterile products, the FTC MUST investigate how the middlemen of GPO and PBM are causing these issues.