21st Century Hearings: Georgetown University November 1 #FTC-2018-0091-D-0018

Submission Number:
Amy Baker
Initiative Name:
21st Century Hearings: Georgetown University November 1
Hello, I am a pharmacist and Director of Pharmacy at a Federally Qualified Health Center. We are a 340B entity, so I have insight not just into retail pharmacy, but also the 340B space. It is this expanded perspective that gives me more insight into the practices of PBMs. I review all of our contracts and watch our diminishing reimbursement. I sent the majority of the attached document to Congressman Walden in August, 2018. I have taken out other issues from my letter and updated a bit to reflect my concern over the anti-competitive practices of CVS Health in particular, although the major PBMs are doing very similar things. In regards to PBMs, I have several concerns: 1. Size and spread of PBMs 2. Discriminatory contracting (both historically and new) by PBMs with 340B pharmacies. 3. Fall of independent pharmacies, especially in rural areas where they are desperately needed 4. Anti-competitive practices Overall, I see CVS (and other PBMs) leveraging their control in the market space to drive out independent pharmacies. I dont understand how companies have been allowed to contract to their direct competitors, and determine the reimbursement for their competitors, without any regulatory oversight. The first oversight that needs to happen is a look at the discriminatory reimbursement for competitors, as well as 340B pharmacies. Are PBMs paying their own pharmacies more than the competitors? Additionally, the entire reach of the company needs to be taken into account. I have not heard any public mention during the merger of acquisition of Wellpartner by CVS and the ramifications of the power it holds. The recent move to force their pharmacies to contract with their own TPA, thus stealing business away from other TPAs is clearly anti-competition. I wanted to take advantage of this comment period to bring these acts to the attention of the FTC. Thank you for reading and considering what I bring forth. Sincerely, Amy Baker, PharmD